
##4000152 Section : Articles <p> We quantified the threats facing 488 species in Canada , categorized by COSEWIC ( Committee on the Status of Endangered Wildlife in Canada ) as extinct , extirpated , endangered , threatened , or of special concern . Habitat loss is the most prevalent threat ( 84% ) , followed by overexploitation ( 32% ) , native species interactions ( 31% ) , natural causes ( 27% ) , pollution ( 26% ) , and introduced species ( 22% ) . Agriculture ( 46% ) and urbanization ( 44% ) are the most common human activities causing habitat loss and pollution . For extant species , the number of threats per species increases with the level of endangerment . The prevalence of threat types varies among major habitats , with overexploitation being particularly important , and introduced species particularly unimportant , for marine species . Introduced species are a much less important threat in Canada than in the United States , but the causes of endangerment are broadly similar for Canadian and globally endangered species . <p> Keywords : endangered species ; threats ; @ @ @ @ @ @ @ @ @ @ are altering the natural world at an unprecedented scale , causing global extinction rates to rise by an estimated three or four orders of magnitude ( Pimm et al . 1995 , May and Tregonning 1998 ) . A worldwide effort to slow or stop this loss of biodiversity is under way , including identification of biodiversity " hotspots " ( Myers N et al . 2000 , Roberts et al . 2002 ) , development of a global protected area network ( Rodrigues et al . 2004a , 2004b ) , prevention of the spread of exotic species ( Myers JH et al . 2000 , Pimentel et al . 2000 , Blackburn and Duncan 2001 ) , and reduction of overexploitation ( Bodmer et al . 1997 , Rosser and Mainka 2002 , Brashares et al . 2004 ) . <p> Information about which species are at risk and what factors threaten their existence is of central importance to planning a successful strategy to slow the loss of the world 's biota . Numerous studies have investigated the threats to endangered species in the United States ( Czech and @ @ @ @ @ @ @ @ @ @ et al . 1998 ) . Collectively , they identify habitat loss , followed by introduced species , as the most common cause of endangerment . It appears , however , that there is strong geographic variation in the causes of endangerment . For instance , in China , overexploitation , not habitat loss , is the major threat to endangered vertebrates ( Yiming and Wilcove 2005 ) . Furthermore , most of the world 's imperiled amphibians are declining for unknown reasons , probably related to disease and climate change ( Stuart et al . 2004 ) . Given such regional variation in patterns of threat , a national conservation strategy needs to be informed by analyses conducted at a national level , recognizing that not all species on national lists will be endangered globally . <p> The Canadian parliament recently passed the country 's most important endangered species legislation , the Species at Risk Act ( SARA ) . Under SARA , the Committee on the Status of Endangered Wildlife in Canada ( COSEWIC ) is charged with producing , updating , and maintaining an official list of species @ @ @ @ @ @ @ @ @ @ COSEWIC are reviewed by the minister of the environment before being granted protection under SARA . But although work is under way to identify Canada 's endangered species , until now no attempt has been made to quantify the threats facing these species , with one notable exception : Kerr and Cihlar ( 2004 ) used remote sensing data to correlate agriculture and agricultural pollution with endangered species density in Canada . However , this analysis was unable to assess the importance of other threats , such as nonagricultural forms of habitat loss and pollution , introduced species , overexploitation , native species interactions , and natural causes . <p> Here we quantify the major threats to Canada 's endangered species . We categorize these causes of endangerment at a broad scale to illustrate general trends and to investigate whether the threats differ among major taxonomic groups or habitat types . We use finer-scale categories of habitat loss and pollution , divided into functional categories of human activity ( agriculture , extraction , urbanization , infrastructure , and human disturbance ) , to determine the ultimate causes of species endangerment . @ @ @ @ @ @ @ @ @ @ with those in the United States ( Wilcove et al . 1998 ) and worldwide ( Baille et al . 2004 ) . Data source and collection <p> Data on the threats ( also called " causes of endangerment " ) to Canada 's extinct , extirpated , endangered , threatened , and special-concern species ( hereafter referred to simply as " endangered " ) were gathered from COSEWIC ( 2006 ) . Following COSEWIC 's definition , we considered a " species " to be any indigenous species , subspecies , variety , or genetically or geographically distinct population of wild flora or fauna . Data were gathered in June 2005 , at which time COSEWIC had identified 500 endangered species from 12 taxa : vascular plants , freshwater fishes , birds , terrestrial mammals , reptiles , marine mammals , molluscs , amphibians , lepidopterans , marine fishes , mosses , and lichens ( table 1 ) . <p> Information provided by COSEWIC was gathered from three sources : ( 1 ) COSEWIC species status reports , ( 2 ) COSEWIC species executive summaries , and ( 3 ) @ @ @ @ @ @ @ @ @ @ reports and executive summaries are written by independent authors and reviewed by COSEWIC 's Species Specialist Groups . As part of its work on species at risk , the CWS ( 2006 ) summarizes the original COSEWIC reports . When the authors of a report identified a threat as " potential " or " hypothetical , " we did not include it as a known threat . We made no attempt to differentiate between historical and current threats , nor between major and minor threats , as this information was almost always unavailable . We were able to gather data on the threats facing 488 endangered species ( 98% ) . Of the remaining 12 species , 8 had only hypothetical or potential threats , and 4 had no identified threats . <p> Following the threat categories recognized by IUCN ( World Conservation Union ) , we grouped the threats to endangered species into six broad categories : habitat loss , introduced species , overexploitation , pollution , native species interactions , and natural causes ( table 2 ) . To provide a more detailed account of the threats to Canada @ @ @ @ @ @ @ @ @ @ table 3 ) ; this was possible for 398 of the 488 species included in this study . <p> COSEWIC status reports are the best source of information on the threats to Canada 's endangered species . However , these reports have at least two limitations . First , the authors may have biases toward listing some threats over others , biases that may differ between taxa or major habitat types . Second , although COSEWIC compiles and analyzes the best available data for each species , its sources are often not of an experimental or even a quantitative nature . We can make no assumptions about how these limitations have influenced our findings . <p> A one-way analysis of variance ( ANOVA ) was used to test whether the average number of threats per species differed among levels of endangerment . Chi-squared tests were used to test for differences in the frequency of the broadscale threats among habitat types , between Canada and the world , and between Canada and the United States . In general , alpha was set at 0.05 for two-tailed tests , but was corrected to @ @ @ @ @ @ @ @ @ @ between Canada and the world , and to 0.01 when comparing Canada and the United States . All analyses were done using SPSS 7.0 ( SPSS 1997 ) . Threats to endangered species <p> Habitat loss , affecting 84% of species , is the greatest threat to endangered species in Canada ( figure 1 ) . Introduced species ( 22% ) , overexploitation ( 32% ) , pollution ( 26% ) , native species interactions ( 31% ) , and natural causes ( 27% ) all affect much smaller proportions of species . Surprisingly , pollution and introduced species , both of which are widely believed to be major causes of species endangerment ( Wilson 1992 ) , are less important than either native species interactions or natural causes , neither of which are even listed as potential threats in similar studies ( Wilcove et al . 1998 ) . <p> Figure 1 . The percentage of endangered species in Canada ( n = 488 ) identified by the Committee on the Status of Endangered Wildlife in Canada in June 2005 as threatened by habitat loss , introduced species , overexploitation @ @ @ @ @ @ @ @ @ @ . <p> Few species ( 30% ) are threatened by only a single cause of endangerment . On average , endangered species face 2.2 of the 6 broadscale threats . The number of threats facing a species varies significantly among levels of endangerment ( ANOVA : F ( 3,484 ) = 5.79 , p = 0.001 ) , increasing from special concern to threatened to endangered species ( 1.99 , 2.22 , and 2.44 , respectively ) . The combined category of extinct and extirpated species has the fewest threats ( 1.94 ) . Because 57% of extinct and extirpated species have not been sighted in the past 50 years ( COSEWIC 2006 ) , the paucity of identified threats for these species is most likely attributable to our lack of knowledge . <p> The relative importance of a threat type varies strongly among taxa ( table 3 ) . While habitat loss is important for all taxa , it is much less of a threat to freshwater fishes , marine fishes , and marine mammals . Overexploitation is the most prevalent threat for marine mammals and marine fishes ( affecting @ @ @ @ @ @ @ @ @ @ important threat for reptiles and terrestrial mammals ( affecting 65% and 47% , respectively ) . Pollution is the second-ranked threat for freshwater fishes ( 51% ) and also threatens a similar proportion of amphibians ( 53% ) . Like Richter and colleagues ( 1997 ) , we found that nonpoint sources ( e.g. , siltation and nutrient inputs ) are the most common form of freshwater pollution . Native species interactions are the second most important threat for birds ( 46% ) , terrestrial mammals ( 47% ) , and lichens ( 57% ) . Natural causes are the second most important threat for amphibians , affecting 58% of species . Over half of Canada 's endangered amphibians are found only in the southern part of the country , within 100 kilometers of the US border ( COSEWIC 2006 ) ; Canada may represent the northern edge of these species ' range . This probably makes them especially susceptible to natural causes of endangerment , which include such factors as severe weather and inherent biological limitations . <p> The fine-scale threat categories in table 3 provide more detailed information on @ @ @ @ @ @ @ @ @ @ 28% ) and agriculture ( 27% ) are the most common causes of habitat loss . Competition ( 10% ) and predation ( 6% ) are the major mechanisms by which introduced species endanger native species . Intentional harvest ( 22% ) , followed by bycatch ( 9% ) , is the most important form of overexploitation . As with the broadscale categories , these trends vary greatly among taxa . Human disturbance , typically some form of recreational activity , is the greatest cause of habitat loss for vascular plants , affecting 42% of species . Bycatch , affecting an astonishing 78% of endangered marine fish , is the most important cause of overexploitation for these taxa , whereas road kills ( 41% ) are one of the most important threats for reptiles . Threats by habitat type <p> To determine whether the prevalence of threat types varies among habitats , we grouped species by their primary habitat and compared the threats facing these groups . We attempted to define each of the 488 endangered species with threat data as being primarily a terrestrial , freshwater , or marine species @ @ @ @ @ @ @ @ @ @ use for each species from Wright and Wright ( 1957 ) , Scott and Crossman ( 1973 ) , Wheeter ( 1975 ) , Straley and colleagues ( 1985 ) , Godfrey ( 1986 ) , Argus and colleagues ( 1987 ) , Banfield ( 1987 ) , Gleason and Cronquist ( 1991 ) , Behler and King ( 1998 ) , COSEWIC ( 2006 ) , and CWS ( 2006 ) . Sixty species commonly used more than one habitat type and were therefore excluded from the analysis , including 16 birds , 13 amphibians , 9 reptiles , 5 marine mammals , 4 freshwater fishes ( anadromous ) , 5 marine fishes ( anadromous ) , 4 terrestrial mammals , and 4 vascular plants . Of the remaining 428 species , 231 were defined as terrestrial , 154 as freshwater , and 43 as marine . <p> The relative importance of the six major threat categories differs significantly among habitat types ( figure 2 ; ? = 127.42 , degree of freedom df = 10 , p < 0.001 ) . Habitat loss is the major cause of endangerment @ @ @ @ @ @ @ @ @ @ habitats , whereas overexploitation is the major cause in marine habitats ( 88% ) . The second most important threat in the terrestrial habitats is native species interactions ( 35% ) , whereas pollution is the second most common threat in freshwater habitats ( 45% ) . Habitat loss is the second most important threat ( 50% ) in oceans , primarily because vessel traffic degrades habitats for marine mammals and commercial fishing damages benthic habitats for fishes and invertebrates . Affecting only 3% of marine species , introduced species seem to be an infrequent threat in the marine environment , presumably because the long-distance dispersal that often occurs in oceans means that oceans have fewer endemic species than do terrestrial habitats ( Davis 2003 ) . <p> Figure 2 . The percentage of Canadian terrestrial ( n = 231 ) , freshwater ( n = 154 ) , and marine ( n = 43 ) endangered species that are listed by the Committee on the Status of Endangered Wildlife in Canada as threatened by habitat loss , introduced species , overexploitation , pollution , native species interactions , or natural @ @ @ @ @ @ @ @ @ @ attempt to link human activities , the ultimate causes of endangerment , to the proximate causes of endangerment shown in table 3 . The proximate threats of habitat loss and pollution -- habitat degradation affect 453 ( 93% ) of Canada 's endangered species . We divided the causes of these threats into five functional categories of human activity : urbanization , agriculture , human disturbance , extraction , and infrastructure . In total , there was sufficient information to determine the sources of habitat degradation for 341 species . <p> Agricultural activity ( 46% ) and urbanization ( 44% ) are the most prevalent ultimate causes of endangerment in Canada . Surprisingly , human disturbance ( 35% ) is a more common cause of habitat degradation than either extraction ( 33% ) or infrastructure development ( 28% ) . The most commonly cited forms of human disturbance were vessel traffic for marine animal species and either all-terrain vehicle use or pedestrian trampling for many terrestrial plant species . <p> Kerr and Cihlar ( 2004 ) found that land use is an excellent predictor of endangered species density in Canada . @ @ @ @ @ @ @ @ @ @ but not on urbanization , human disturbance , extraction , or infrastructure . In our analysis , the relative importance of these nonagricultural categories of land use as a cause of endangerment is surprising . A possible explanation may be that urbanization , agriculture , human disturbance , extraction , and infrastructure development are highly associated causes of endangerment in space ( Czech et al . 2000 ) . Hence it may be difficult to conclude from remote sensing data whether it is agricultural activity alone or one of its associated threats , or both , that is actually endangering species . Comparisons with the world <p> We compared the threats facing endangered species in Canada with the threats facing globally endangered species , using data from Baille and colleagues ( 2004 ) . Summarizing data provided by IUCN , Baille and colleagues ( 2004 ) catalogued the threats facing 3829 globally endangered species of amphibians , birds , and mammals . When comparing our results with theirs , we included only these three taxa ( n = 148 ) . In their analysis , Baille and colleagues ( 2004 ) @ @ @ @ @ @ @ @ @ @ our study , we combined their category " human disturbance " with " habitat loss . " We also combined " persecution " and " incidental mortality " with " overexploitation . " In our study , when a pathogen was not identified as being introduced , it was assumed to be native and included as " species interactions " To match our study , we combined Baille and colleagues ' ( 2004 ) " disease " and " changes in native species dynamics " to form " species interactions . " Finally , we retained only " natural disasters " from our original category " natural causes . " <p> The prevalence of threat types differs significantly between Canadian and globally endangered species ( figure 3 ; ? = 38.42 , df = 5 , p < 0.001 ) . While habitat loss is the most prevalent threat both in Canada ( 79% ) and globally ( 87% ) , it affects a slightly greater proportion of globally endangered species ( ? = 7.865 , df = 1 , p = 0.005 ) . Introduced species affect a similarly small @ @ @ @ @ @ @ @ @ @ 16% ; ? = 0.47 , df = 1 , p = 0.49 ) . Overexploitation threatens significantly more endangered species in Canada than globally ( 46% and 23% , respectively ; ? = 43.68 , df = 1 , p < 0.001 ) . The differential importance of overexploitation in the two studies can largely be explained by the relative importance of the three taxa in the two studies . Baille and colleagues ' ( 2004 ) study included proportionately more amphibians and fewer mammals than did our study . If we adjust our taxa to the same relative frequency as those in Baille and colleagues ' ( 2004 ) study , there is no significant difference in the importance of overexploitation to Canadian ( 26% ) and globally ( 24% ) endangered species ( ? = 0.815 , df = 1 , p = 0.367 ) . Natural disasters affect significantly more endangered species in Canada than globally ( 16% and 9% , respectively ; ? = 8.86 , df = 1 , p = 0.003 ) , perhaps because many of Canada 's endangered species exist at the @ @ @ @ @ @ @ @ @ @ 2004 , Warman et al . 2004 ) and are therefore more susceptible to severe weather events . <p> Figure 3 . The percentage of endangered species in Canada ( n = 148 ) and worldwide ( n = 3829 ) that are affected by habitat loss , introduced species , overexploitation , pollution , native species interactions , and natural disasters . Comparisons with the United States <p> We compared the threats facing endangered species in Canada with those in the United States , using data from Wilcove and colleagues ( 1998 ) . In their study , Wilcove and colleagues cataloged the threats facing 1880 imperiled species , subspecies , and populations of vertebrates , invertebrates , and plants . However , their categories of threat differed from ours ; they did not include native species interactions and natural causes as potential threats , but instead included disease , which was found to affect only 3% of species . To permit direct comparison between the two studies , these categories were excluded . <p> Habitat loss and introduced species are the leading threats to imperiled species in the United @ @ @ @ @ @ @ @ @ @ ( figure 4 ) . While habitat loss is equally important in both countries ( ? = 0.42 , df = 1 , p = 0.52 ) , the importance of introduced species as a cause of endangerment in the United States contrasts strongly with our results , which identify introduced species as the least common broadscale threat in Canada ( ? = 113.74 , df = 1 , p < 0.001 ) . We believe the heightened importance of introduced species in the United States can be explained by the large number of Hawaiian species included in Wilcove and colleagues ' ( 1998 ) analysis and the widespread effects of introduced species on the islands . For instance , the authors included 456 Hawaiian plants and birds , of which 99% were threatened by introduced species . Excluding Hawaiian species , the importance of introduced species did not differ significantly between the United States ( 31% ) and Canada ( 27% ) for plants and birds , the only taxa for which data are available ( ? = 1.22 , df = 1 , p = 0.27 ) . <p> @ @ @ @ @ @ @ @ @ @ 488 ) and US ( n = 1880 ) endangered species that are affected by habitat loss , introduced species , overexploitation , and pollution . <p> Aside from disease , Wilcove and colleagues ( 1998 ) found overexploitation to be the least important threat in the United States , affecting only 17% of imperiled species ( figure 4 ) . This contrasts strongly with Canada , where we found 32% of species to be threatened by overexploitation ( ? = 51.13 , df = 1 , p < 0.001 ) . While this discrepancy may be due in part to real differences between the two countries , we believe it is largely attributable to the definition of overexploitation . Wilcove and colleagues ( 1998 ) included only overharvest , to the exclusion of bycatch , persecution , and accidental mortality . Redefining our category for consistency with theirs , we find that overharvest threatens only a slightly higher proportion of endangered species in Canada than in the United States ( 22% and 17% , respectively ; ? = 6.83 , df = 1 , p = 0.009 ) . Conservation @ @ @ @ @ @ @ @ @ @ Wilcove et al . 1998 , Baille et al . 2004 ) , showed that habitat loss is the greatest threat to endangered species in Canada . Affecting 94% of terrestrial species , habitat loss is caused primarily by agricultural and urban land conversion . The establishment of terrestrial protected areas is a common and effective response to protect species from habitat loss ( Balmford et al . 1995 ) . Unfortunately , much of the habitat used by Canada 's endangered species exists on private land ( Barla et al . 2000 ) . To protect these species , landowners will need to be compensated for encouraging the persistence of endangered species on their property ( Polasky et al . 1997 ) , which is explicitly recognized in Canada 's new endangered species legislation ( SARA 2006 ) . On the negative side , SARA provides less habitat protection for terrestrial species than the United States ' Endangered Species Act ; in Canada , critical habitat for endangered species is strictly protected only on federal lands , accounting for only 4% of the terrestrial habitat south of 60 north latitude @ @ @ @ @ @ @ @ @ @ all migratory birds and aquatic species receive habitat protection under SARA . In addition , a " safety net " process can provide habitat protection for species not on federal lands . <p> We found that overexploitation was the second most common threat in Canada , in contrast with other researchers ' findings for the United States and for the world . Moreover , overexploitation was the most important threat facing Canadian marine species . To protect these species , there is a strong initiative to establish a system of marine protected areas , both in Canada and globally ( Balmford et al . 2004 ) . Unfortunately , most analyses suggest that 20% to 30% of oceans need to be protected to sustain world fisheries in the remaining habitat ( Balmford et al . 2004 ) . This is an ambitious goal , given that only 0.5% of oceans are currently protected , compared with 11.5% of terrestrial habitats ( Meir et al . 2004 ) . <p> Introduced species are the least important threat in Canada . This contrasts strongly with the findings of previous studies ( Wilcove et @ @ @ @ @ @ @ @ @ @ with popular opinion ( Wilson 1992 ) . However , when Hawaiian species are excluded , introduced species are about equally important in the United States and Canada . Furthermore , introduced species are rarely a threat to Chinese ( 3% ; Yiming and Wilcove 2005 ) or globally threatened species ( 16% ; Baille et al . 2004 ) . It appears that introduced species may be a less important threat , at least on continents , than previously thought . <p> Natural disasters and natural causes emerge as more common threats in Canada than globally . This surprising result does not mean that natural processes alone are major threats to Canada 's biodiversity . Of the 237 species for which either natural disasters or natural causes are listed as threats , only 15 species are threatened by no other cause . On average , these 237 species are threatened by 1.6 other broadscale threats and 2.5 other fine-scale threats . <p> Many endangered species in southern Canada have stable core populations in the United States ( Bunnell et al . 2004 , Warman et al . 2004 ) . @ @ @ @ @ @ @ @ @ @ is what efforts , if any , should be made to protect these endangered peripheral populations . Peripheral populations are thought to be more susceptible to extinction and therefore harder to conserve ( Hoffman and Blows 1994 ) . However , recent studies have shown that under conditions of range contraction , core populations appear to suffer extirpation first , leaving only peripheral populations ( Channell and Lomolino 2000 , Laliberte and Ripple 2004 ) . Determining the value of peripheral populations will prove critical for conservation policy in Canada . <p> In general , our findings present few major surprises . There are important differences in the causes of endangerment in Canada among major habitats and taxa , but many of the marked differences among regions of the world are more apparent than real . Finally , most species are affected by more than one threat , with the number of threats increasing with the level of endangerment . Effective conservation strategies must be able to address multiple threats simultaneously . Acknowledgments <p> We thank the Committee on the Status of Endangered Wildlife in Canada and all of its contributing @ @ @ @ @ @ @ @ @ @ species in Canada , without which this research would not have been possible . We are grateful to David M. Green , Katsky Venter , Michelle Nol , and three anonymous reviewers for helpful comments on an earlier version of the manuscript , and to Jaiseema Seyan and the students of Biology 457 at Concordia University , who initiated this research project . Our research was financially supported by a Discovery Grant to J. W. A. G. and an Undergraduate Student Research Award to O. V. from the Natural Sciences and Engineering Research Council of Canada . Table 1 . The number of species in each taxon listed as extinct , extirpated , endangered , threatened , or of special concern by the Committee on the Status of Endangered Wildlife in Canada , June 2005 . PREFORMATTED TABLE Table 2 . Definitions of broadscale and fine-scale threat categories . PREFORMATTED TABLE Table 3 . Summary of the threats facing endangered species in Canada , expressed as the percentage of endangered species affected . PREFORMATTED TABLE 
##4000951 ( Contributions from " Soledad Cross History " published at www.aclusandiego.org made with permission of the ACLU of San Diego and Imperial Counties. ) 1954-1990 <p> The annual Thomas Guide published by Thomas Brothers Maps refers to the landmark as the " Mount Soledad Easter Cross . " Easter Sunday 1954 <p> With the permission of the San Diego City Council , the Mount Soledad Memorial Association ( MSMA ) dedicates the cross on Mount Soledad as a tribute to veterans of World War I , World War II , and the Korean Conflict . 1989 <p> On May 31 Philip Paulson and Howard Kreisner file a lawsuit claiming the religious symbol 's presence on state land violates provisions of the U.S. and California constitutions . They do all of their legal research and writing as well as court presentations without legal representation . <p> A small plaque dated November 11 that recognizes the site as a memorial to veterans is mounted to the fence surrounding the base of the cross . 1991 <p> On December 3 U.S. District Court Judge Gordon Thompson Jr . rules in favor @ @ @ @ @ @ @ @ @ @ the cross is permanently positioned inside a public park and maintained at taxpayers ' expense . Kreisner resigns from the case shortly after the ruling and the City of San Diego Historical Site Board designates the cross and the surrounding park as historical sites . 1992 <p> On June 2 San Diego voters approve Proposition F , which allows transfer of ownership of a portion of Mount Soledad Natural Park to a private , non-profit corporation for maintenance of a historic war memorial . 1993 <p> The city appeals the 1991 district court decision to the U.S. Ninth Circuit Court of Appeals , which upholds the decision , ruling that the mere designation of the cross as a war memorial is n't enough to satisfy the " no preference clause " of the California Constitution . The City and County of San Diego thereupon petition and are granted a hearing en banc ( a vote by the entire twenty-eight judges of the court ) . They lose by a unanimous decision . 1994 <p> The city sells 224 square feet of land at the base of the cross to the Mount @ @ @ @ @ @ @ @ @ @ states its intention to keep the cross as part of its proposed war memorial and the city does n't solicit or consider bids from any other prospective buyers of the land . <p> On October 10 the City and County of San Diego petition the U.S. Supreme Court with a writ of certiorari . The Court declines to hear the appeal . 1996 <p> Though it has become a tradition for Christian groups to hold Easter sunrise services at the cross site , this year University of California at San Diego Political Science Professor Peter Irons is the first to secure the permit for that date and proceeds to conduct a controversial but well-attended secular sunrise event for people of all religions and no religion . 1997 <p> On September 18 Judge Thompson rules that both the negotiated sale of the cross site to the MSMA and the size of the plot sold violate two separate provisions of the California Constitution . Thompson writes : " Both the method of sale and the amount of land sold underneath the Mount Soledad cross do not cure the constitutional infirmities outlined in this @ @ @ @ @ @ @ @ @ @ again attempts to sell the land to a private group . Five bids are submitted , including one from the Freedom From Religion Foundation . The bid from the MSMA ( the highest ) is accepted and a half-acre of land around the cross is sold for $106,000 . <p> Paulson receives the " Freedom Fighter Award " from the Rationalist Society of St. Louis . 2000 <p> On February 3 Judge Thompson upholds the 1998 transfer . Paulson appeals , and the ACLU joins the appeal as his co-counsel . <p> The MSMA constructs six concentric granite walls around the base of the cross designed to hold plaques purchased by individuals wishing to honor a veteran 's military service . An American flag , small pillars , and brick pavers are also installed to honor community and veterans ' groups and supporters of the memorial . All told , the MSMA will spend over $900,000 on the improvements and sell over 1300 plaques. 2001 <p> In August a three-judge panel of the U.S. Ninth Circuit Court of Appeals affirms Judge Thompson 's ruling . 2002 <p> Paulson 's petition for @ @ @ @ @ @ @ @ @ @ The case is reargued on March 21 before an eleven-judge panel of the Ninth Circuit . <p> On June 26 the court finds that the city 's sale of the cross to the MSMA violates Article XVI , section 5 , of the California Constitution , which prohibits government from affording any financial advantage or subsidy to religion . <p> The city again appeals to the U.S. Supreme Court , which again declines to hear the case . 2004 <p> The La Jolla American Legion Post 275 , which created the MSMA , votes unanimously to support moving the cross to the nearby Mount Soledad Presbyterian Church . The San Diego Regional Chamber of Commerce lobbies the city council to support the move . In exchange for Paulson dismissing his suit , the parties agree to move the cross to the church , allowing the MSMA to maintain an interest in the war memorial and replace the cross with a nonsectarian symbol appropriately recognizing all veterans . <p> The settlement terms are presented to the city council on July 27 but the council conditions its acceptance on the outcome of a @ @ @ @ @ @ @ @ @ @ voters . Proposition K specifically asks voters to give the city authorization to sell a portion of Mount Soledad to the highest bidder . <p> On November 2 voters reject Proposition K by a large margin . <p> Two members of Congress , Randy Cunningham and Duncan Hunter , slip a rider into a $300 billion appropriations bill to designate the memorial a national monument , specifically requiring the continued presence of the cross . This allows the federal government to accept a yet-to-be-offered donation of the land from the city and directs the National Park Service to help maintain it . A restraining order temporarily bars the transfer to the federal government . <p> On December 19 Paulson is named 2004 Atheist of the Year by American Atheists California . 2005 <p> On March 8 the San Diego City Council votes against a proposal to transfer the land to the National Park Service . <p> A petition signed by over 100,000 San Diego County residents causes the City Council to reconsider its decision to transfer the land . On May 16 , after rejecting in a 5-4 vote a proposal @ @ @ @ @ @ @ @ @ @ the Council votes 6-3 to include a ballot measure in the forthcoming special Mayoral election . <p> Paulson files a pre-election challenge in state court , claiming the proposed transfer violates the California Constitution . <p> On July 26 voters approve Proposition A to transfer the Mount Soledad Veterans Memorial property to the federal government . <p> On September 3 , in response to Paulson 's challenge , Superior Court Judge Patricia Yin Cowett issues a temporary restraining order barring the transfer . Lawyers on each side present their arguments on October 3 . A key issue is the status of the area as a secular war memorial , given that it was n't developed as a memorial until ten years after the first lawsuit . <p> An October 1 New York Times article reports that , because San Diego City Attorney Michael Aguirre personally opposes fighting to keep the cross , he brought in a lawyer from a conservative Christian legal advocacy group to make the city 's case . " It 's clearly unconstitutional , " he declares , adding that the case has gone on for so long @ @ @ @ @ @ @ @ @ @ rulings . " It 's like San Diego does n't recognize the need to comply with the law as a fundamental principle . " <p> On October 7 Judge Cowett finds the ballot measure unconstitutional . Her ruling states : " Maintenance of this Latin Cross as it is on the property in question , is found to be an unconstitutional preference of religion in violation of Article I , Section 4 , of the California Constitution , and the transfer of the memorial with the cross as its centerpiece to the federal government to save the cross as it is , where it is , is an unconstitutional aid to religion in violation of Article XVI , Section 5 . " <p> In December Philip Paulson 's lawyer James McElroy asks a San Diego Superior Court judge to order the city of San Diego to pay his legal fees for the October victory . 2006 <p> On January 13 Judge Cowett rules that the city must pay for McElroy 's fees , but exactly how much is yet to be determined . The city plans to appeal . <p> On @ @ @ @ @ @ @ @ @ @ Mount Soledad cross must be removed from the property within ninety days or the city of San Diego will be fined $5,000 a day thereafter . <p> In a May 4 article in the San Diego Union-Tribune , William Kellogg , president of the MSMA is quoted as saying the group is prepared to have the cross moved to private property nearby and place another fitting symbol for veterans at the memorial . " We feel it 's very important that the cross be saved , " he says . " The location of the cross is not the primary issue . " In the same article , Paulson 's attorney James McElroy says , " It 's time to end seventeen years of litigation and it 's time for the taxpayers to end footing the bill for futile litigation . " He also reports receiving numerous death threats , one as recently as the day before , as a result of handling the case . <p> On May 11 Mayor Jerry Sanders asks President George W. Bush to use the power of eminent domain to take the city-owned property on @ @ @ @ @ @ @ @ @ @ May 23 the San Diego City Council votes 5-3 to appeal Judge Thompson 's May 3rd order to remove the cross . <p> Mayor Sanders announces on June 2 that the city has filed an appeal of Thomson 's order . The city also asks that the appeal be ruled on by June 8 , after which they will comply with the order if the appeal is n't granted . <p> On June 21 a three-judge panel of the U.S. 9th Circuit Court of Appeals declines to step in and suspend the $5,000 daily fine that will be imposed on the city if the cross is n't removed by August 1 . <p> On June 26 San Diego County Congressmen Duncan Hunter ( R-52nd ) , Brian Bilbray ( R-50th ) and Darrell Issa ( R-49th ) introduce HR 5683 , a bill to preserve the Mount Soledad Veterans Memorial in San Diego , California , by providing for the immediate acquisition of the memorial by the United States . <p> On July 3 Supreme Court Justice Anthony M. Kennedy issues a temporary stay in favor of the city and the @ @ @ @ @ @ @ @ @ @ <p> On July 7 , in a four-page decision , Justice Kennedy grants the City of San Diego 's request for a stay pending a ruling on the city 's appeal . <p> On July 19 HR 5683 passes in the House of Representatives by a vote of 349-74 . <p> On August 1 the Senate approves ( through procedural " unanimous consent " ; not a recorded vote ) an eminent domain plan to transfer the cross and the land underneath it to federal control . Plaintiff Paulson seeks a court-ordered injunction and stay by stopping the transfer until all legal issues have been adjudicated in the courts . <p> On August 11 Paulson and newly named Plaintiff Steve Trunk file a new lawsuit in the U.S. District Court of Southern California . U.S. District Court Judge Barry Moskowitz agrees to rule and decide by September 2006 if both the land transfer and the presence of the cross on federal land are unconstitutional . <p> On August 14 President Bush signs HR 5683 . <p> On August 21 the ACLU , representing the Jewish War Veterans of the United States @ @ @ @ @ @ @ @ @ @ Defense Secretary Donald Rumsfeld , charging that the continued display of the Mount Soledad cross on federally owned land unlawfully entangles government with religion . The suit asks the Court to order the cross ' removal . <p> In a September 1 story , the San-Diego Union-Tribune reports that Paulson was diagnosed on July 31 with terminal liver cancer . Paulson says doctors estimated he has four to twelve months to live if chemotherapy is unsuccessful . <p> On September 3 Paulson receives the 2006 Humanist Pioneer Award from the American Humanist Association and the 2006 Church and State Award from Americans United for Separation of Church and State . <p> On September 7 the House Judiciary Committee approves the Public Expression of Religion Act , HR 2679 , first introduced in September 2005 . The bill heads to the House floor for a full vote while similar legislation is pending in the Senate ( S 3696 ) . These bills would bar courts from awarding attorney 's fees to prevailing parties bringing suit under the establishment clause , and would make it much more difficult for citizens to challenge governmental @ @ @ @ @ @ @ @ @ @ The spirit behind this action was clearly articulated in a July 26 New York Sun article in which Rees Lloyd , a lawyer and unit commander with the American Legion , was quoted as saying , " I 'm appalled at the notion that the ACLU or any other purported public interest law firm would be suing veterans ' memorials and then seeking taxpayer-funded attorney fee awards .. The ACLU has lost all moorings and common sense and rationality and proportionality .. It 's become the Taliban of American liberal secularism . " <p> On September 26 HR 2679 passes in the House of Representatives by a vote of 244 to 173 . <p> By Philip Paulson <p> 
##4000952 IN THE MONTHS AFTER the 2004 election , when the red states were said to have voted on the basis of their " moral values " many observers noted that the sleazy television shows and movies so energetically denounced by the traditionalist and Christian right tended to get their highest ratings in the same parts of the country most populated by such people . ( They noted , as well , that some of the family pathologies that traditionalists decry are found at high rates among these most vocal proponents of " family values . " ) <p> Some took this as a clear indication of the hypocrisy of conservatives : what they denounce , they also secretly enjoy . They are n't as concerned about morality , this critique declared , as they pretend to be ; while they maintain a posture of devotion to righteousness they 're indulging their forbidden impulses in hidden ways . <p> Jimmy Swaggart writ large . <p> But I do n't think " hypocrisy " is the most illuminating way of seeing this phenomenon . Not if hypocrisy is understood as @ @ @ @ @ @ @ @ @ @ comes from looking at the matter of " moral structure . " <p> From my discussions of morality with religious traditionalists , I 've gleaned that many of them assume that people who do n't believe in their firm and strict moral structures -- people who do n't believe in God , the Ten Commandments , or inviolable and absolute rules of moral conduct -- must be living lives of sin and debauchery . They ca n't understand ( and often seem unwilling even to believe ) that people like Humanists might be living the kind of well-ordered lives , as hard-working and law-abiding citizens responsible and dedicated to their families , that they themselves strive to live . <p> Their failure to understand how nonbelieving " liberals " can live moral lives is actually the reverse side of the same coin from the liberals ' imputation of hypocrisy to those red-staters who watch Desperate Housewives and may also have disordered family lives . <p> These misunderstandings stem from the failure of the two groups to recognize their differing moral structures . DIFFERENCES IN THE LOCUS OF CONTROL <p> A student @ @ @ @ @ @ @ @ @ @ America 's Moral Crisis " came up with the most apt image . It did n't matter much to her whether her society has a lot of enforced rules . She 's got her moral beliefs firmly inside her -- a kind of endo-skeleton , she called it . <p> We had been talking about the distress American traditionalists have felt at the erosion of a social consensus about the straight-and-narrow path . For them , she said , morality seemed to be a kind of exo-skeleton . This was her image to capture their reliance on external moral structures -- laws , punishments , and so forth -- to keep them within the moral confines in which they believe . <p> In that perspective , the assumed anomalies or hypocrisies of certain traditionalists make greater sense . <p> It becomes clear why such people -- possessing intense moral concerns combined with a reliance upon external moral structures to keep their own forbidden impulses in check -- would support a state that enforces moral rules and a social culture that stigmatizes those who violate those rules . It really is a @ @ @ @ @ @ @ @ @ @ around them fails to be clear in its rules and strict in its enforcement . <p> For one whose moral structure is cast in that exo-skeleton form , the absence of external moral authority seems necessarily to imply the outbreak of moral anarchy . That 's the logic implied by the famous line falsely attributed to Fyodor Dostoevski : " If God does not exist , everything is permitted . " It 's what lies behind the fear that if gays are allowed to marry , marriage generally would somehow be threatened , including the sanctity of one 's own . <p> To the liberal with the endoskeleton structure , both of those seem like logical non sequiturs . And , logically , perhaps they are . But they bespeak a psychological reality . If the outside structure breaks down , who knows what one might do ? <p> Liberals have often failed to understand how the loosening of society 's moral standards , rules , and sanctions can be genuinely threatening to the moral order of those with the exo-skeleton structure . They have n't appreciated the plight of people @ @ @ @ @ @ @ @ @ @ help in doing it . <p> Likewise , many liberals have responded with anger , unleavened by understanding , to the tendency of some traditionalists to try to impose their moral views on others . It is their dependence on the strength and integrity of the external moral order that drives many " exo-skeletons " to crusade to make the whole world around them conform to the moral system to which they themselves are striving to adhere . The unspoken and generally unacknowledged need is : please , society , be morally strict enough to keep me on the straight-and-narrow path . INTEGRITY AND HYPOCRISY : THE CHALLENGE TO THE EXO-SKELETONS <p> These fears of traditionalists reflect a lack of integration -- the morality not fully integrated into the psyche . <p> St. Paul lamented : " For the good that I would I do not : but the evil which I would not , that I do . " Truly , he wanted to do the good . But it is not entirely true that the evil he did was something he wanted not . For a part of him @ @ @ @ @ @ @ @ @ @ it . <p> So was Paul a hypocrite for doing what he declared himself to be against ? And are the red-staters hypocrites if they indulge -- perhaps more even than the liberals -- the forbidden desires ? <p> Well , yes and no . Yes , in that they are n't practicing what they preach . And that does represent a lack of integrity . But the " dishonesty " involved is not about lying to others so much as it is a natural outgrowth of the identification with only a part of the self , the moral part , with a concomitant sense that the other part , with the forbidden desire , is the not-I . <p> So that is the hypocritical part : the failure to embrace the whole truth about the self -- that is comprised not only of the " righteous " part but of the " sinner " part as well . <p> If the moral order of the surrounding society weakens , the person with a moral exo-skeleton is genuinely threatened -- not just regarding his conduct , but also even regarding his @ @ @ @ @ @ @ @ @ @ Those of us with the endo-skeleton structure -- who can live moral and orderly lives even if we live in an " anything goes " society -- can reasonably be tempted to feel superior to those with the exo-skeleton dependency on the moral sanctions of a more straight-and-narrow society . <p> And indeed there are theories of moral development according to which the internalization of moral order is a more " advanced " form of moral development . <p> But , at this point in our nation 's history , we can see that the quest for advanced consciousness has many dimensions , and neither side of America 's divide has aced the course . This is part of the cost of our cultural polarization -- two forms of moral blindness , very different from each other but also two sides of the same coin . <p> Just as the cultural right has damaged the United States because of its failure to acknowledge its inner sinner , the left has damaged the nation through its failure to recognize its inner moral structure . <p> This was one of the greatest shortcomings @ @ @ @ @ @ @ @ @ @ simply tore down a great many of our society 's moral structures and assumed that all would be well . We had half-baked theories of human nature , and of society , that justified " letting it all hang out " and " doing our own thing " and " if it feels good , do it . " <p> History has shown that we were naive . Not all has been well . Indeed , I would argue that this naive miscalculation is part of what has led , ultimately , to the rise of the more destructive forces from the right , embodied by the administration of George W. Bush . LIVING OFF OF OUR MORAL CAPITAL <p> What many in the counterculture did , I believe , was to look at themselves in their " liberated " state and imagine that they saw human nature in its pristine condition . But in reality , most of the middle class youth -- brought up in the 1940s and ' 50s -- who comprised the counterculture had already internalized a great many of the disciplines , moral and otherwise , @ @ @ @ @ @ @ @ @ @ could engage in the cultural revolution of liberation and then go on to become effective , middle class , liberal professionals with well-ordered lives . <p> The loosening of the moral structures of society has impacted , rather , the heirs of the counterculture -- younger people who did n't form their characters in the tighter environments of the 1940s and ' 50s but in the culturally looser decades since . <p> Veteran teachers have long complained that each successive wave of students shows signs of a loosening in discipline of various kinds . The culture has grown trashier , the demands of society have become less stringent , the culture of indulgence has grown deeper -- and all this has led to a visible cultural decline . <p> Of course many of those who carried with them the older structures have managed to raise children whose lives are also fairly well ordered . But even there it is a diminishing cultural capital that we are living off of . And I expect that among the endo-skeletons -- in the absence of some kind of cultural renewal -- the necessary forms @ @ @ @ @ @ @ @ @ @ to attenuate . <p> But it is on the other side of the cultural divide -- in the realm of the exo-skeletons -- that the loosening of the moral order has proved most dangerous . <p> It is n't only that the cultural right , more dependent on the external restraints , becomes more likely to succumb to forbidden impulses -- like sailors come to port . More dangerous for society is that the particular nature of the right 's moral vision -- its relative harshness and its punitiveness -- transforms the impulses of the human animal into something darker . <p> Fragile orders tend also to be harsher -- tyranny being seen as the surest means to avoid anarchy . And , accordingly , a moral order that is less internalized , being more fragile , tends also toward harshness . <p> Thus the morality of the exo-skeletons tends to denigrate the human nature it seeks to control . This morality also tends to be more punitive in its approach to control -- glad to invest big sums in a brutal prison system ( whether or not such punishments actually @ @ @ @ @ @ @ @ @ @ condoning the torture of enemy combatants , passionately committed to the death penalty , and building its worldview around a highly punitive Lord of the Universe . <p> And the harsher the morality -- the more the interaction between cultural demand and human nature is conducted in the form of war -- the more the feelings inside the human being turn toward rage ( at the wounds inflicted ) , toward a desire for power ( to counteract the powerlessness of being small in a world that has declared war on you ) , and toward a lust for vengeance ( for all the punishment and rejection inflicted ) . <p> The harsh morality of the cultural right thus engenders within the human spirit a kind of wolf . It is a wolf such as Shakespeare described in Troilus and Cressida : PREFORMATTED TABLE <p> And the same harsh morality that goads this wolf into life will also -- when it is intact -- help confine that beast to its cage . <p> The loosening of the cage of the nation 's social morality had one meaning , therefore , among @ @ @ @ @ @ @ @ @ @ 's exoskeletons . It is as though a boat was tipped by the left , but it was the right that got wet . <p> It was n't just the natural id that was loosed on the cultural right , but also unleashed were those impulses that their subcultures harshness had made dark . We in the counterculture who wanted to liberate , for example , the natural sexual energies of the human creature also , unwittingly , weakened the checks on the lust for power , on greed , on self-aggrandizement . <p> Morality , it turns out , is of a piece . And so is our culture . <p> And so it could be said the wolf has now broken from its cage . Draped in the national flag , it prowls society from the precincts of power , fooling enough people into thinking that what it 's bringing is order . RECONSTRUCTING THE CAGE <p> In any event , there are better options for order . But their realization is a significant cultural achievement . Good order in the human realm does n't happen except through wise @ @ @ @ @ @ @ @ @ @ twofold . It is n't only to remove that wolf from power but it is also to help reconstruct the cage -- those structures of morality that kept it in check . Ideally , we 'd do much better than merely " reconstruct " the moral cage of an earlier era . That would be an improvement over this loosening , which has unleashed these dark forces . But still better would be to find a better means of containment , or perhaps even a more harmonious form of domestication that does n't need to abuse the creature it brings into the social fold . That old order was far from ideal . <p> The counterculture recognized the oppressiveness of the old order but it failed to realize that a truly beneficent revolution is n't accomplished by the storming of the Bastille . And it failed to recognize that the movement of a culture to its next , more advanced form is a long-term and difficult process . <p> What is needed this time around is n't a wanton rejection of the old structures , replacing them with nothing . As @ @ @ @ @ @ @ @ @ @ us together . <p> We must understand , that is , that the moral endo-skeleton is not nothing . It is something achieved through human development . And , more , we need to understand that the endo-skeleton does n't come from nothing . It is the internalization of the order the growing human encounters around him or her . <p> And no skeleton at all is a recipe for falling apart . <p> PHOTO ( BLACK &; WHITE ) <p> By Andrew Bard Schmookler <p> <p> Andrew Bard Schmookler is the creator of the website www.NoneSoBlind.org . He is also the prize-winning author of The Parable of the Tribes : The Problem of Power in Social Evolution and Debating the Good Society : A Quest to Bridge America 's Moral Divide . He can be reached at andythebard@comcast.net . <p> 
##4000953 DR . JOSEPH L. " JOEL " ANDREWS spent two weeks in the New Orleans area in December 2005 as a physician volunteer for the American Red Cross Hurricane Katrina Disaster Relief Programs . Three months after the hurricane had hit , he witnessed firsthand the storm 's devastating effects on residents in the city 's various communities . <p> MY FIRST NEW ORLEANS HOUSE CALL is one I will certainly never forget . I was working in the Red Cross office in Metairie when I received an urgent request to help evaluate a very agitated man in Mid City . I left the office immediately and drove south on Interstate 10 to North Carrollton Street . <p> I met Arlo , a retired psychologist and Red Cross volunteer mental health worker from California , in the parking lot of an abandoned Burger King . Arlo had visited a client , Floyd S. , the previous day at the request of a Red Cross emergency crew . Floyd had told the crew that he would die if he did n't receive his medications soon . Arlo had found @ @ @ @ @ @ @ @ @ @ of schizophrenia , manic-depressive disorder , and hypertension , along with other medical conditions . <p> I followed Arlo down a side street . The wooden houses on this block had received major hits , both from Hurricane Katrina 's high winds and from the storm 's floodwaters . Most sported bright blue FEMA tarps , designed to stop water from leaking through roofs whose shingles had been torn off by Katrina 's strong winds . Tall debris piles littered sidewalks on both sides of the street , blocking some access points . Cars were coated with dried flood muck . <p> Arlo and I entered the shotgun-style house where Floyd was staying . Although the building was elevated about four feet off the ground , the flood surge had done its dirty business . The house smelled dank from muck and mold . Filthy clothes and furniture were strewn haphazardly in the front room . Horizontal brown lines on the walls about four feet above the floor were evidence of the levels that earlier flooding had reached . Clearly , no one had done any cleanup here in the three @ @ @ @ @ @ @ @ @ @ on a bed in the back room of the house . We asked him to come out to the front room , which he did reluctantly . I asked him to sit and settled down across from him on a filthy rocking chair . Then I tried to take a medical history . Floyd told me that he was fifty-three , but his unkempt gray dreadlocks , lined face , jumbled speech , and unruly white beard gave him the appearance of a man twenty years older . <p> I ascertained that Floyd had n't taken his psychiatric or blood pressure medicines in more than three weeks , since he was unable to get his prescriptions filled . The more we talked the more manic and incoherent Floyd became . Then he stood up and ran out the door . <p> Arlo and I went outside and saw Floyd talking to three men on the front porch of a house a few doors down . We approached the men , who told us that Floyd became increasingly agitated when he could n't take his meds . Neither his wife nor his @ @ @ @ @ @ @ @ @ @ so he often came to them . The men sometimes brought food to him , and Earl , a tall man in yellow Lakers sweatpants , said that he had occasionally paid for Floyd 's medications in the past . Agreeing that he needed immediate hospitalization to get him back on his medications , Arlo and I took Floyd back to his own home . <p> Standing in the street , I used my cellphone to call East Jefferson Hospital ( in suburban Metairie ) to talk to the emergency room doctor who had written Floyd 's prescriptions three weeks earlier . He was n't there , so I called the hospital 's record room in an effort to learn more about Floyd 's diagnoses and treatments . The clerk there told me she could n't release any information unless I faxed her a release signed by the client . I told her I did n't have access to a fax machine and there was no way I could get this man to sign a release in his current condition . The clerk hung up . <p> I then called the @ @ @ @ @ @ @ @ @ @ who could provide transportation to the hospital . Five minutes later a squad car pulled up , then another , and then another , until finally a squadron of six police cars blocked the street . A posse of twelve New Orleans police officers emerged from their cars and walked toward us . They chatted amiably to each other , like attendees at a law enforcement convention . When they asked if Floyd was armed , we said we did n't think so . A stocky officer frisked him , then snapped handcuffs around his wrists . Understandably , Floyd 's demeanor worsened as he sat forlornly on the front steps . <p> I asked a police officer , " Why all the cops and the cuffs ? " <p> " For a show of force , " she replied . " The cuffs are because recently an officer got shot in a similar situation . " Six squad cars then departed . One hauled away a handcuffed and now severely distraught Floyd . <p> Two days later I returned to Floyd 's neighborhood with Tim , another mental health worker @ @ @ @ @ @ @ @ @ @ blacks and whites , clustered on the street in front of his house . One man in preppy attire , definitely out of place in this neighborhood , identified himself as a mystery writer . He said he 'd come to reclaim a book that he had previously lent to Floyd . The writer sported a pair of hiking boots hanging by their laces around his neck . He 'd brought them for Floyd , he said , who was currently shoeless . <p> Floyd 's neighbors told us that the police had taken him to Ochsner Foundation Hospital in Jefferson . They brought him back at three o'clock in the morning with more paper prescriptions but without any actual drugs . <p> We found Floyd on the steps of a ramshackle religious shelter several blocks away . As I climbed the steps , Floyd smiled , greeted me by name , and started singing " Somewhere Over the Rainbow . " Why that ? I thought . Then I remembered . The first time I met Floyd I had introduced myself as " Dr. Andrews . You know , like @ @ @ @ @ @ @ @ @ @ shoulder and told him that it was really Judy Garland who sang The Wizard of Oz song ; that Julie Andrews had starred in The Sound of Music . Floyd just kept singing " Over the Rainbow " anyway . He looked pleased with himself . I too was pleased that he was in a better mood and " with it " enough to smile and reach out to make some social connection . <p> During my two weeks making home visits in New Orleans I saw firsthand Katrina 's effect on people . I also saw the storm 's effect on infrastructure , especially in the most heavily damaged Lower Ninth Ward , where powerful waves from the breached levees had pulverized wooden houses and left only splintered timbers . <p> I visited sections of New Orleans with moderate house damage , such as Mid City and Lakeview and the suburbs of Metairie , Kenner , and Westwego . Many of these neighborhoods still had no electric or water services . When I visited these houses with Molly , a Red Cross caseworker , I discovered that most of the @ @ @ @ @ @ @ @ @ @ been depleted by months of living as evacuees . After returning to New Orleans these homeowners dipped further into savings to rehabilitate their gutted homes , often at the mercy of scarce and expensive contractors . <p> The evening after Floyd sang to me on the porch , I attended a panel discussion by the Health/Social Services Committee , part of Mayor Ray Nagin 's Bring Back New Orleans Commission . The news was n't good : thirteen of seventeen public health clinics were destroyed by Katrina , only two of New Orleans ' eleven hospitals were then open , and most doctors offices were still closed . Most patient records were destroyed or lost . Most evacuees had moved elsewhere without their medications , prescriptions , or records . And about 50 percent of evacuees had no health insurance . The New Orleans healthcare system , always shaky , now lay shattered in Katrina 's wake . There were no medicines for Floyd and thousands of other residents of New Orleans because these residents had close to nothing -- no money , no insurance , no telephone , no transportation @ @ @ @ @ @ @ @ @ @ U.S. Surgeon General David Satcher lauded the residents of New Orleans for their " resiliency and commitment . " He noted , however , that the trauma and violence many children endured during Katrina made it likely that they , as well as many adults , would experience Post-Traumatic Stress Disorder , increasing their tendency toward violent behavior as they grew older . <p> Next , the chairs of six subcommittees ( Primary Care , Specialty Care , Hospitals , Public Health , Environmental Health , and Social Services ) presented their proposals for improving health in New Orleans . They noted sadly that Louisiana had placed forty-ninth out of fifty states in measures of the quality of healthcare before Katrina . Their wish lists that night included measures that did n't exist before the storm , such as improved cooperation and coordination between hospitals , universal access to all health facilities , and better evacuation plans to prevent a similar catastrophe . <p> I noted two important shortcomings with the hundred or so proposals on these planners ' wish lists : no mention was made about how all these desirable @ @ @ @ @ @ @ @ @ @ a timetable for when they would actually take place . <p> Several days later I made my way down unlit corridors leading to a warren of small rooms in a building on Burgundy Street , not far from the French Quarter . I was making a house call on Clara D. , an eighty-seven-year-old lady living alone with her black dog , Girlie . A former shrimp factory worker , Clara had been evacuated to nearby Kenner after Katrina ; she had returned to her cluttered two rooms only a short time before we met . <p> In addition to multiple health problems , Clara was most worried about her lack of finances . She received $579 a month from Social Security and $75 in food stamps , which she said would soon decrease . Her rent was $400 a month . Little was left to pay for medical care and drugs . And , like most elderly shut-ins in the Big Easy , Clara had no phone , no transportation , no doctor or clinic , and no accessible pharmacy . <p> I spent more than thirty minutes on my @ @ @ @ @ @ @ @ @ @ to no avail . Each published resource number I called accessed only a recorded message , which merely listed many more numbers to call . No actual services were provided . I felt like shouting , " We need services , not numbers ! And we need them now ! " <p> Despite the optimistic dreams of its healthcare planners , New Orleans still has a long way to go to create an effective medical care infrastructure to provide equitable delivery of high-quality healthcare for all . Only one half of pre-Katrina hospital beds are usable . Six of nine hospitals remain shuttered . Of the ninety healthcare clinics that existed pre-Katrina ( where most of the poor got their care ) less than twenty are functioning now . Nursing home beds are scarce . <p> Much has been said and written to explain the catastrophe that was New Orleans before , during , and after Katrina : inadequacy of the levees , lack of evacuation planning and execution , slowness of government agencies such as FEMA to respond to the emergency , and so on . <p> What can we @ @ @ @ @ @ @ @ @ @ Orleans ? <p> As previously stated , Louisiana was ranked forty-ninth out of fifty states in healthcare outcomes before Katrina . Post-Katrina plans abound to improve its healthcare system , but the essential ingredients -- adequate funding , careful planning , and coordination -- are still questionable . Clinics , private practices , hospitals , pharmacies , and patient transportation all still need strengthening over a year later . <p> The fact that many poor New Orleanians , mostly blacks , remained for days or weeks in a severely flooded city because there were no means to evacuate them came as a surprise to many Americans . The fact that many elderly , frail people were left behind to die unnecessarily was a cause for shame throughout the United States . Can widespread poverty be addressed successfully in a city that has lost half its population and many more jobs ? It will require the political will , careful and coordinated planning , much work , and much money to remedy . <p> Perhaps city officials and healthcare planners should figure out how to more effectively harness the underappreciated strengths demonstrated @ @ @ @ @ @ @ @ @ @ , and ill . The compassion and care , demonstrated so admirably by Floyd 's neighbors every day , might well help to address the significant challenges the city now faces in bolstering healthcare . <p> Finally , will important lessons be learned in time ? If another powerful hurricane occurs , will the New Orleans healthcare system be strong enough to withstand the new strains placed on an already overburdened system ? This issue must be faced here and now , not somewhere over the rainbow . <p> PHOTO ( BLACK &; WHITE ) <p> PHOTO ( BLACK &; WHITE ) <p> By Joseph L. Andrews , M.D. <p> <p> Dr. Joseph L. " Joel " Andrews of Concord , Massachusetts , is a practicing internist and a Lecturer in Medicine at Tufts University School of Medicine in Boston . He is also a freelance writer and author . <p> 
##4000957 QUESTIONS ABOUT THE PROPER place of religion in a democracy and the separation of church and state remain in the news . In the United States , legal and social battles about the proper place to draw the line between religion and government are being waged around the issues of abortion , gay marriage , faith-based social services , and other well-publicized flash points of conflict between sacred beliefs and secular authority . And with the political influence of religious conservatives evidenced in the 2004 presidential election , the issue of religious influence on affairs of state is likely to remain a matter of importance and controversy for the foreseeable future . Thus the secularism and church-state separation of liberal democratic theory are under renewed attack . So reexamining the principles underlying secular government becomes not simply a matter of leisurely philosophical speculation but one of extreme political and practical urgency . <p> The principle of separation of church and state is essential for providing for and preserving both religious freedom and the long-term continuation of the peaceful stability of a well-ordered , liberal democracy -- where human @ @ @ @ @ @ @ @ @ @ goods and where more human freedom is recognized as better than less . But leaders of what is commonly called the religious right have been attempting to tear down the Jeffersonian wall of separation between church and state ( as did many religionists in Thomas Jefferson 's own day ) . So it is necessary to clarify what is at stake in this struggle . <p> Many people do n't realize that the phrase " separation of church and state " is n't found anywhere in the Constitution of the United States . The celebrated First Amendment simply places a prohibition on Congress by saying that " Congress shall make no law respecting an establishment of religion , or prohibiting the free exercise thereof . " This language severely limits the actions of the federal government but says nothing about limitations on state governments or on religion itself . On the contrary , for many alive at the time of ratification , one intention of the restraint on Congress appears to have been to give state governments free rein in religious matters . It was n't until 1868 , when the @ @ @ @ @ @ @ @ @ @ , that states were constitutionally required to be religiously neutral . <p> While various Supreme Court decisions have since used the language and imagery of the " wall of separation between church and state , " the phrase originated in the famous letter Thomas Jefferson wrote to the Danbury , Connecticut , Baptist Association during his first term as president in 1802 . In this letter he also wrote that " religion is a matter which lies solely between man &; his god . " This was a principled position : later in his Autobiography he made it clear that his thinking included " the Jew and the Gentile , the Christian and the Mahometan , the Hindoo , and infidel of every denomination . " Jefferson had the genius to recognize that the fundamental issue of religious freedom extends beyond the simple mutual toleration of different Christian denominations for each other . <p> Before examining the importance of the separation of church and state in liberal democratic theory , it is necessary to clarify two important presuppositions of that theory . The first is a certain view of human nature @ @ @ @ @ @ @ @ @ @ first ) is the distinction between the private lives of citizens and the public arena in which legislation or public policy is proposed , debated , and then either approved or defeated . <p> Liberal democratic theory is committed to a general philosophic view of human nature that can be traced to the Enlightenment . Are human equality and human freedom intrinsic goods ? Is it the role of government to protect and nurture these goods ? Does the ultimate source of legitimate political authority lie in the citizens of a republic ? Liberal democratic theory answers in the affirmative and views humans as rational beings capable of determining and regulating their own social , economic , and political affairs . The " liberal " aspect of liberal democratic theory takes its meaning from the philosophical rather than the political usage of the term -- a meaning that is derived from " liberty . " Both Immanuel Kant and Thomas Jefferson endorsed this view of human nature . Reacting against the dominant Christian theological view that human nature was fundamentally corrupt and in need of divine guidance and deliverance from itself @ @ @ @ @ @ @ @ @ @ human beings as fundamentally rational and profoundly educable . Knowledge resulting from free , unfettered inquiry was viewed as providing not only the basis for understanding the natural world but also for humans understanding themselves , including their social and political selves . Thus human beings came to be regarded as embodying the ability to consider and value the common good and to provide for the social and political arrangements that improve the human condition . The notion of self-government had to be proceeded by the belief that human beings are capable of self-government . <p> Clarifying the distinction between the private lives of the citizens of a democracy and the public arena in which public policy and legislation are debated and formulated is crucial to liberal democratic theory . John Locke made clear , for example , in A Letter Concerning Toleration , that the business of the civil magistrate and the business of the church must be completely distinct . Locke maintained that " the only business of the church is the salvation of souls " and the only circumstances in which the state has an interest are those @ @ @ @ @ @ @ @ @ @ injury . <p> The distinction between public and private life is one Jefferson used as the crux of his justification for his wall separating church and state . Not only is religion a private matter in Jefferson 's view , there are also pernicious effects due to the mingling of private matters of religion and public affairs of state . James Madison concurred , claiming that the papal system , wherein church and the state are n't separated , represents " the worst form of governments . " The wall of separation was thus intended to prevent what Thomas Paine later called the " adulterous connection of church and state . " <p> At the time the U.S. Constitution was framed there was considerable debate amongst the various states concerning whether government should establish recognized connections between religion ( i.e. , Protestant Christianity ) and the state or whether it should explicitly disestablish such connections . Some delegates , insisting that the United States was a Christian nation , tried but failed in an attempt to include such recognition in the Constitution . Given the pressure from various religious groups and @ @ @ @ @ @ @ @ @ @ , it is an often-overlooked act of statesmanship of enormous proportion that the delegates to the Constitutional Congress were able to set aside their own particular beliefs in the framing of the document . The de facto separation of church and state created in the Constitution by this absence of references to Christianity or other religions was widely and strongly criticized by many religious leaders at the time . Debates in state legislatures concerning adoption of the Constitution were often heated , with much concern expressed about religious freedom and with several states insisting that a guarantee of religious freedom be included in a bill of rights . This debate led to the First Amendment in 1789 . The movement toward complete disestablishment of religion in all of the states was a slow , gradual , multifaceted process that involved Congress , the Office of the President , the Supreme Court , and state legislatures and continued until the mid-twentieth century . Indeed , some might say it still continues today . <p> But if a democratic government is to nurture and maximize human freedom then it must provide constitutional protections @ @ @ @ @ @ @ @ @ @ including religious beliefs . In order to do this , a constitutional democracy needs to provide constitutional guarantees that prohibit civil penalties , denial of civil privileges , or granting of special civil privileges on the basis of religious beliefs ( or lack thereof ) on the part of any citizen . <p> Locke 's words are still directly on point in this regard : his claim that " it is above all things necessary to distinguish exactly the business of civil government from that of religion " provides a mechanism to put an end to the otherwise endless religious controversies in a pluralistic society that prevent the peaceful and smooth functioning of a well-ordered society . The fundamental claims that are to be incorporated into the constitution must be justifiable to all citizens , and this can not be done if the justification appeals to one set of religious beliefs rather than another . In order to construct a constitution on principles that all citizens will agree to , one must appeal only to human reason . This is the lesson that is preserved in philosopher John Rawls ' Principle @ @ @ @ @ @ @ @ @ @ which considers such matters as " who has the right to vote , or what religions are to be tolerated , or who is to be assured equality of opportunity , or to hold property . " <p> However , not everyone agrees that the fundamental constitutional issues should be debated and decided by appeal only to reason . For example , Nicholas Wolterstorff maintains that the separation of public civic life from private religious life discriminates against religious believers by requiring them to act politically while denying or ignoring their religious beliefs , and that setting their religious beliefs aside in such circumstances might very well be contrary to or a violation of those religious beliefs . This situation generates a paradox for liberal democratic theory , according to Wolterstorff , since liberal democratic theory is based upon the fundamental commitment to equality and freedom ; however , for the religious person , such a commitment might be based upon religious belief . In his view , by denying the religious person the right to appeal to religious belief to justify the most fundamental principles of democracy , liberal democratic @ @ @ @ @ @ @ @ @ @ person , and the religious person would presumably be denied the freedom to act upon his or her religious belief . <p> To respond to Wolterstorff 's criticism of the separation of public civic reason and private religious belief , it is necessary to be clear about exactly what his complaint is . In order to generate the apparent paradox , it appears that Wolterstorff must be claiming that the religious person 's commitment to equality and freedom is based solely and exclusively upon religious belief . Ought a person be allowed to appeal to religious belief as the exclusive justification for valuing equality and individual freedom on the constitutional level and would the failure to allow such an appeal be paradoxical to liberal democratic theory ? The answers to these questions become apparent when the questions are generalized . <p> Of course a person might hold a belief p on religious grounds , but p might also be justified to others on non-religious grounds in a manner that appeals to reason . The Principle of Political Legitimacy would require the religious person in such a situation to translate the basis @ @ @ @ @ @ @ @ @ @ public reason in order to justify p to others . If p is a claim that can be justified only by an appeal to some religious authority or tradition , which does not play the same justificatory role for others , then according to the Principle of Political Legitimacy the religious person has no right to expect the adoption of p on the constitutional level . If p is some belief supportive of liberal democratic theory , then it initially appears that the part of liberal democratic theory that endorses individual freedom would be undermined since the religious person would be denied the freedom to promote ( and perhaps establish ) p on the basis of religious belief alone . However , if there is no general prohibition against the introduction of p solely on religious grounds and p is a belief that is contrary to or incompatible with the fundamental values of equality and freedom , then it would be impossible to provide constitutional guarantees for those fundamental values . Different people might come to the public table of constitutional debate with different religious agendas , based solely on religious @ @ @ @ @ @ @ @ @ @ the hurdle of the same kind of intractable disagreements that had plagued Western Europe for centuries during its religious wars . <p> To jumpstart the process of framing a democratic constitution , the private religious beliefs of those doing the framing must be set aside . And this is exactly what the framers of the Constitution of the United States were able to do . <p> Now compare this to the current situation in Iraq . In the latter case we have a modern-day laboratory experiment of an attempt to develop a democratic government and frame a constitution . What is to be the role of Islam in the resulting structure ? The Shiites and the Sunnis each want a piece of the pie , as do the non-Arab Kurds , while members of the Baath Socialist Party have been denied participation . The situation is strikingly similar to the one that faced those responsible for drafting the U.S. Constitution . <p> There are , of course , other important issues to be resolved in Iraq . But in order to provide for a peaceful , stable , well-ordered society , @ @ @ @ @ @ @ @ @ @ the relationship between religion and whatever kind of state emerges from the process . If the expectation is to arrive at a result that is comparable to the liberal democracy of the United States , then the answer to the question of what the relationship should be between religion and the state must be the same . The only general and permanent guarantee of religious freedom and protection of religious minorities is a constitutional separation of religion and government . Thus the shadow of Thomas Jefferson looms large over the process of drafting the constitution for a democratic Iraq . If the eventual result is to be a democratic government that values and protects individual liberty and equality , then the answer to the question of what governmental role Islam is to have is clear : none . <p> There are two differences between Christianity and Islam that are worth explaining , since they are directly related to the two philosophical preconditions of liberal democratic theory . First , as a result of the Protestant Reformation , Protestantism recognized and adopted the view of human nature discussed above , according to @ @ @ @ @ @ @ @ @ @ . In contrast to Roman Catholicism , Protestantism became non-hierarchical and , one might say , more democratic . Second , much of Protestant Christianity ( although certainly not all of Protestantism , such as the Puritans ) came also to separate theology from politics and religion from the everyday civic lives of individuals . This is why the distinction between the private , individual religious life and the public , civic secular life , which is crucial for Jefferson 's separation of church and state , became possible . <p> This crucial separation is n't a part of early Islam , nor is it to be found in Orthodox Judaism or Confucianism ( nor , one might add , in Roman Catholicism , early Protestantism , and many forms of American Christian fundamentalism ) . Moreover , there is little optimism that the distinction can be drawn for Islam in a way that separates religion from political or civic life , since Muhammad gave laws that explicitly connect theology with politics . The significance of the lack of this distinction for the prospects of a peaceful , well-ordered liberal democracy @ @ @ @ @ @ @ @ @ @ now insist that Iraq must be an Islamic country just as many fundamentalist Christians now insist that the United States must be a Christian country . <p> Indeed , the separation of religion and state , the separation of the spiritual and the secular , which is essential to liberal democratic theory , is the very source of what some Muslims take to be the corruption of Western democracies . Such a separation is not only unacceptable to them but is regarded as complete anathema to Islamic thought . Thus the separation of religion and state is not only regarded as a political mistake , it is regarded as a theological mistake as well . In this regard , perhaps ironically , fundamentalist Islam , Orthodox Judaism , and fundamentalist Christianity have much in common . <p> On the constitutional level , there can no more be an Islamic democracy than there can be a Christian or Orthodox Jewish democracy . A religious liberal democracy is an oxymoron . A liberal democracy designed to protect and maximize human freedom and to provide for equality of opportunity and treatment must not only @ @ @ @ @ @ @ @ @ @ is this prospect of secularization that most threatens some fundamentalist Muslims , since secularization is seen as posing a direct threat to their religion . <p> Because one of the most basic philosophical preconditions for a liberal democracy is establishing the wall of separation between religion and state , the future in this respect does n't look promising . To date , Turkey is the only previously Islamic country that is now a democracy . And recently , devout religious believers have forced some concessions and compromises from the state that raise questions about the long-term viability of Turkey 's democracy . Although Israel is often blithely referred to as a democracy , it is n't a liberal democracy but a very limited one -- a closed democracy -- in which democratic guarantees are prescribed for a limited subset of citizens . For example , the state of Israel does n't recognize any civil ceremony for marriage . Only the Orthodox Jewish ceremony is recognized as legal , and no inter-religious marriages are allowed . <p> To best ensure that a society is secure , stable , and peacefully well ordered @ @ @ @ @ @ @ @ @ @ protected from the incursion of religion in all forms and on all levels . It does n't take a religious jihad to threaten a liberal democracy ; it only takes allowing the " the first experiment on our liberties , " as Madison writes -- the first wedge of religion into the structure of the state . <p> Certainly not all fanatics are religious , but the ones who are tend to operate on the same principle : that some religious belief or claim must be placed in the position of ultimate authority . The religious fanatic who opposes abortion by bombing abortion clinics acts on the same principle as the religious fanatic who burns an embassy in protest of so-called blasphemous cartoons published in the embassy 's home country . Both are resorting to violence to damage the state in order to prompt a change in its laws or policies on the basis of some religious belief . Both are religious fanatics acting upon religious beliefs that are immune to reason . The only difference is in the magnitude of the attacks and the number of victims . Both are @ @ @ @ @ @ @ @ @ @ <p> Among those who at present debate the relationship between church and state , there would undoubtedly be more agreement about the necessity for the separation on the constitutional level than there would be about the necessity for the separation ( and the meaning of separation ) within a constitutional democracy . Once a democratic constitution is in place , as the long history of conflicts and court decisions in the United States makes clear , fixing the boundaries between religion and the state becomes trickier . On the legislative level , where individual laws and public policies are determined , what is the proper role of religious beliefs ? There must be additional restraints operative that establish a prima facie obligation upon citizens to refrain from appealing to privately held religious beliefs in the public forum in which the affairs of state are conducted . The difficulty will be in justifying restraints upon appeals to religious beliefs given the constitutional guarantees of the disestablishment of religion ( that is now taken as prohibiting any governmental endorsement of religion ) and the free exercise of religion ( that is now taken @ @ @ @ @ @ @ @ @ @ According to Robert Audi in his book Religious Commitment and Secular Reason , a citizen in a liberal democracy has a prima facie obligation to appeal only to secular reason or to be sufficiently motivated only by secular reason to support or oppose legislation or policy in the public arena . If a person is originally motivated solely by religious belief or has a religious belief as the sole reason for advocating or opposing a particular action by the state , then that belief or that reason needs to be reformulated into a rationale or an argument that appeals to human reason . <p> Perhaps the most significant feature of religious reason , and perhaps the feature from which all the other differences between religious reason and secular reason derive , is the oft-touted claim by believers that religious reasons carry an infallible supreme authority that guarantees the truth of such claims against all potential epistemic defeaters . However , allowing appeals to such religious reasons , held to be infallible , in the public arena where laws and public policies are made , would result in what Audi calls a @ @ @ @ @ @ @ @ @ @ the death , " that is , an epistemic dead end from which there is no retreat or escape . This would obviously threaten the peaceful and well-ordered stability of a liberal democracy . <p> But , is not disagreement and conflict simply one of the prices to be paid for a liberal democracy ? There are numerous cases where the free exercise of religion and privately held religious beliefs have apparently come into conflict with public reason . The followers of Christian Science , for example , often refuse conventional medical treatment for their minor children on the basis of religious beliefs . Some fundamentalist Muslim parents force female circumcision upon their minor daughters on the basis of religious beliefs . Gay marriage and abortion are opposed by many on the basis of religious beliefs . And some support the public display of the Ten Commandments on government property on the basis of religious beliefs . <p> In each of these cases , the proper approach is to separate the religious interest from the civic interest and to require , in those cases where the religious interest is said to @ @ @ @ @ @ @ @ @ @ civic concern be put in nonreligious terms . Most importantly , in a pluralistic , liberal democracy this must be done in a way that guarantees equal protection , in this case religious parity , for all . <p> How might equilibrium amongst competing religious beliefs and equal protection ever be achieved unless a wall of separation between church and state is maintained ? The simple , straightforward answer is that it can not . Equal treatment and the establishment of religion are inversely proportional . To the extent that one religion is given preferential or privileged treatment , others are denied equal treatment . <p> Locke maintained that citizens should be allowed free exercise of religion except in cases where such exercise harms society or poses the possibility of social harm . It is certainly permissible for people to believe whatever they prefer on whatever grounds they choose in their private lives . However , if those same beliefs are used as the basis for legislation or public policy , it is easy to see that a line has been crossed where the introduction of private religious beliefs into the @ @ @ @ @ @ @ @ @ @ exercise of religion to the public arena threatens to destroy the underlying theoretical framework of the very democratic guarantee of the free exercise of religion itself . In a liberal democracy the exclusion of religion from the government arena is the only way to provide for the peaceful stability of a well-ordered society that protects the free expression of religion in the private lives of citizens . <p> By James F. Harris <p> <p> James F. Harris is Haserot Professor of Philosophy at the College of William and Mary . He is the author of numerous articles in both domestic and foreign journals and the books Against Relativism : A Philosophical Defense of Method and Analytic Philosophy of Religion . <p> 