by Jeff Davis
Consider the plight of Tantalus, a mythical Greek king and son
of Zeus who revealed certain information the gods wanted to keep
secret. The punishment divined for his transgression involved
standing in a pool of fresh water for eternity, which flowed away
each time he bent over to drink from it. Branches thick with fruit
tempted him, only to move out of reach each time he stretched
for it. The word tantalize is the legacy of this Greek king, "To
tease or torment by presenting something desirable to the view
but continually keeping it out of reach."
Now consider the photojournalist, a reporter who conveys information
not through words, but through images. Many news events, from
routine items like traffic accidents and scheduled meetings of
governmental bodies to dramatic cases of enormous tragedy are
routinely excluded from photographic newsgathering, usually by
law enforcement officials. These photographers, whose professional
reason for being is to document visually what occurs in life,
are tantalized by sometimes being prevented, on a regular basis,
from documenting what is happening in their communities.
Reporters whose dispatches are written or spoken have the opportunity
to use second-hand information while covering a story. If the
reporter was not an eye witness to the event, a credible and complete
report can be compiled through interviews and exchange of information.
Photojournalists don't have this luxury. By necessity, the photojournalist
must actually view the scene, as the event happens, to gather
the news product before distribution of the information is possible.
For the ethical news organization, there are no re-takes on news
events. Henri Cartier-Bresson, a pioneer photojournalist who has
shaped the field described it:
"But for photographers, what has gone, has gone forever. From that fact stem the anxieties and strength of our profession. We cannot do our story over again once we've got back to our hotel. Our task is to perceive reality, almost simultaneously recording it in the sketchbook which is our camera."
Journalism has been described as "the first draft of history,"
and as such the historical record will be entirely incomplete
whenever a photographic record does not exist. Edward Steichen
was in charge of the U.S. Navy photographic unit during World
War II, an element that produced over a million negatives of the
Navy's effort during the war. Steichen observed:
"Any photograph that is made—the very instant it is completed, the very instant the button is pressed on the camera--becomes a historical document. Its use as such will depend largely on historians."
(In a cruel twist, almost the entire collection of these Navy
photographs has never been seen. The unit carefully packaged,
cataloged and cross referenced the negatives, shipped them to
Washington, D.C., and they have never been seen since.)
A 1936 farm labor dispute in Salinas, California received extensive
photographic coverage from newspapers and newsreel companies.
A historian later noted:
"But perhaps the most lasting legacy of the Salinas images was the way they verified the importance of on-the-spot news photography. . . . The function of news photographers at Salinas had simply been to provide the look and feel of events the public could not witness, and what print reporters, no matter how fluent, could never hope to adequately convey."
The issue of personal feelings and the photographer's desire to
do his/her job are not important; this is not an attempt to make
life easier for news photographers because they are frustrated
by not getting their way wherever they go. A larger issue is raised
due to the unique requirements of access necessary for photographic
documentation of the news. If photographers are arbitrarily denied
access to newsworthy events, there is nothing to publish. If there
is nothing to publish, government officials (the police impeding
access) have essentially imposed a prior restraint on publication--not
in the same vein as the classic Pentagon Papers case, but in a
more subtle, before the fact fashion.
In short, unnecessary restrictions placed on photographic newsgathering
are a form of prior restraint.
There has always existed an adversarial relationship in this country
between the government and the press. Thomas Jefferson's famous
thought on the press, "Were it left to me to decide whether
we should have a government without newspapers, or newspapers
without a government, I should not hesitate a moment to prefer
the latter," did not prevent him from complaining bitterly
about the press when he served as president.
Illustrating news events has been important ever since the technology
to accomplish illustration existed. Prior to the advent of photography,
newspapers illustrated news stories with woodcuts, produced as
an artist's view of an event he witnessed, or an interpretation
from a witness or news account.
After the invention of photography, editors quickly realized the
value of photographs to document the news. Due to the mechanical
nature of the photographic process, news photos would be accepted
and believed as an accurate view of a distant event.
Film maker Andre' Bazin saw the development of photography as
a radical event in history:
"The objective nature of photography confers on it a quality of credibility absent from all other picture-making. . . . Between the originating object and its reproduction there intervenes only the instrumentality of a nonliving agent. For the first time an image of the world is formed automatically, without the creative intervention of man."
Starting in 1842,woodcuts were made using photographs as a source,
and on March 4, 1880 the New York Daily Graphic published a photograph
of a squatter's camp using the halftone process. This technological
innovation, still used today, permits the accurate reproduction
of photographs at high speed by turning continuous-tone photographs
into a series of dots.
Television's evolution over the last 50 years from World's Fair
oddity to ubiquitous presence has increased the importance of
image-dependence of news coverage. The needs for the visual news
gathering processes of television and still photography are, for
the most part, identical. There are some differences, but for
the purposes of this discussion, photography refers generally
to both print and television imaging.
There are certain situations where photographic newsgathering
is strictly controlled, and are not germane to this discussion.
The issue of cameras in courtrooms, both at the state and federal
levels, is a separate topic, and will be touched on only to state
that there has been an incredible increase of photographic coverage
nationwide in courtrooms in the last ten years, with no adverse
effect on the court system. In addition, restrictions on photographing
military installations and activities, as covered by parts of
the Espionage Act (18 U.S. Code section 795) and related acts
will not enter into the discussion. These laws are very specific,
usually relating to military installations, and while they are
tangential to this issue, they are nonetheless outside the scope
due to unique distinctions in the law.
When speaking with working photojournalists, anecdotal reports
indicate that police agencies at all levels, acting either independently
or at the direction of other government officials, habitually
work to prevent access to news situations to photojournalists.
News Photographer magazine, the journal of the National Press
Photographers Association (NPPA), routinely caries stories of
photographers who have been arrested while attempting to cover
news events. In a survey of the last five years of the monthly
publication, over 50 cases of arrest were documented in the magazine.
The NPPA is the largest group of professional photojournalists
in the U.S., with over 8000 members, but this reporting of arrests
cannot be considered complete for a nationwide total, which is
unknown.
A survey in 1987 reported that 24% of the working photojournalists
responding had been barred from an open governmental meeting,
and 6% had been arrested for crossing a police line. In an interesting
breakdown, the author reported that male photojournalists were
more often barred from government meetings than were female photojournalists,
and that television photographers were kept out of meetings most
often. This strengthens the argument that denial of access is
arbitrarily applied.
Three examples of the problem: two photographers were arrested
on April 21, 1993, as they looked to find a vantage point to photograph
the Branch Davidian compound in Waco, Texas two days after it
burned to the ground. The pair, both veteran photographers, from
the Associated Press and the Houston Chronicle, reportedly did
not cross any police line, resist arrest or fail to cooperate
in any way. They were arrested at gunpoint, held incommunicado
for over eight hours, their film was confiscated without a search
warrant or subpoena, and were required to post the maximum bond
after being charged with a misdemeanor offense. It can only be
concluded that officials were sending a message to other photographers
in the area to comply with restrictions, regardless of their legality
or rationality.
In Iowa, when a corporate plane crashed near Dubuque in April,
1993, killing the governor of South Dakota and seven other people,
law enforcement officials removed news photographers from the
scene as soon as they were identified as news photographers, permitting
them an access point only if they stood on a public highway some
three-fourths of a mile from the scene. Even when the photographers
had permission from adjacent landowners, and were more than 300
yards from the scene using telephoto lenses, they were removed
under threat of arrest. And while professional photojournalists
were prevented from recording the activity, neighbors of the farm
where the crash occurred were allowed to remain on the scene,
sometimes standing within the crash site, and were not prevented
from taking photographs.
One state Senator in the Iowa Legislature tried to ban the use
of telephoto lenses by photographers covering the Senate chamber
in 1993. The Senate already severely limits the locations photographers
may shoot from, and the Senator rationalized his proposal by saying
that he didn't think someone should be photographed without their
knowledge, and that "it's disruptive." He did not explain
how it would be disruptive for someone to be photographed without
their knowledge, but he did equate the ban on telephoto lenses
to the already existing ban on flash equipment.
That actual arrests are not more common relate to the common sense
of most photographers who will go to great lengths to avoid arrest,
and when confronted with the threat of arrest will back down or
find some other way to cover the event. The conventional thinking
in newsrooms is that if a photographer is arrested, he/she was
not effectively doing the job. As a result, police routinely,
and as we will see wrongly, deny access to working photojournalists
at newsworthy events.
The fact that some journalists (reporters) are admitted, while
other journalists (photographers) are excluded, or when photographers
are excluded from areas where members of the public are allowed,
is evidence that photojournalists are being prevented from exercising
a specific civil right--the First Amendment right to engage in
the freedom of the press. The U.S. Supreme court has not provided
us with definitive rulings on the issues presented here, but a
case can be complied from some Court rulings, and by a collection
of cases from lower courts.
We will see that courts have:
1) Determined that the loss of First Amendment freedoms results
in an irreparable injury to an individual.
2) Newsgathering does have limited First Amendment protection.
3) Newsgathering, when protected under the First Amendment, cannot
be arbitrarily restricted due to type or category of media.
4) Government officials cannot seize the work product (film or
video tape) of news photographers.
5) Law enforcement officials cannot assault photographers to prevent
them from engaging in news gathering.
6) Restricting photographers from locations where the public or
other journalists are allowed is not permissible.
In short, journalists have a right to gather the news, news photographers are journalists, and news photographers cannot be excluded because they report with a camera instead of a pen. News photographers should not be physically prevented from doing their job, and when their work product, in the form of film or videotape is seized, the government official seizing the film is preventing publication.
To support the specific links in the chain, we first turn to a
1976 case, Elrod v. Burns, a labor dispute involving the Cook
County Sheriff's office, where the Court held:
"It is clear therefore that First Amendment interests were either threatened or in fact being impaired at the time relief was sought. The loss of First Amendment freedoms, for even minimal periods of time, unquestionably constitutes irreparable injury."
While this was not a press case, it is clear that the Court is
cognizant of a time factor when dealing with First Amendment issues.
In addition, this case is often cited in press cases to support
the concept of irreparable harm.
The arrow of time cannot be restrung if a court later determines
an error was made. And while the press freedom issue is paramount
and immediate in this concern, part of the "irreparable injury"
is the loss of historical documentation resulting from this type
of control.
The Court has also explicitly stated that the press has a limited
First Amendment right to gather the news. In Branzburg v. Hayes
Justice White said in the Court's opinion:
"We do not question the significance of free speech, press, or assembly to the country's welfare. Nor is it suggested that news gathering does not qualify for First Amendment protection; without some protection for seeking out the news, freedom of the press could be eviscerated."
In Richmond Newspapers v. Virginia Justice Stevens in a concurring
opinion said,
"Today, however, for the first time, the Court unequivocally holds that an arbitrary interference with access to important information is an abridgement of the freedoms of speech and of the press protected by the First Amendment. . . . I agree that the First Amendment protects the public and the press from abridgement of their rights of access to information about their government."
There has been a longstanding battle over what protection should
exist for the press, and where the limits are for newsgathering.
In this paper, we are concerned with limits that are understood
to be fairly settled: access where the public is permitted, access
where other news media representatives are allowed, and reasonable
access to newsworthy events (accidents, crimes and disasters,
for example).
The last situation has the most tenuous base, and this is not
a call for unlimited access to plane crash sites or crime scenes
for photographers. Officials have a necessary and legitimate basis
for protecting crime and accident scenes, or preventing injuries
at a chemical spill, for example. However, it is becoming increasingly
common for police officials to deny any access to scenes, and
to remove photographers to locations where any type of newsgathering
is impossible.
There have been many cases where officials have attempted to restrict
access to certain reporters or media outlets that they, for some
reason, disapprove of. These cases have routinely been settled
in favor of the media.
The Quad City Community News Service was a so-called "underground
newspaper," and was an irritant to the police department
in Davenport, Iowa. The police denied a reporter from the paper
access to police department records that were routinely available
to other media outlets. The U.S. District Court held in 1971 that
this was an obvious denial of equal protection.
"No showing merely of a rational relationship to some colorable state interest suffices to justify a classification between media permitted access to the reports and others which are not so permitted. Any classification which serves to penalize or restrain the exercise of a First Amendment right, unless shown to be necessary to promote a compelling governmental interest is unconstitutional." [Emphasis in original]
While officials cannot discriminate based on the type of media
outlet, neither can they dictate individuals from those media
outlets that they will admit to open meetings.
In a 1973 case, Borreca v. Fasi , the mayor of Honolulu prevented
a reporter from the Honolulu Star-Bulletin, who had been on the
city hall beat for two years, from attending a regularly scheduled
press conference in the mayor's office. It was found that there
was no reason, other than the mayor's objection to the content
and tone of this reporter's stories to exclude him from the press
conference. The decision held:
"The limitations that may be placed by state action on this right of access are determined by a balancing process in which the importance of the news gathering activity and the degree and type of the restraint sought to be imposed are balanced against the state interest to be served. Where the First Amendment rights are involved, the asserted state interest must be compelling and the proposed state action must be the least restrictive means available for the asserted government end."
In both these cases, the state must have a "compelling interest"
in restricting access to open information or meetings.
While government officials cannot legally restrict access in most
cases, neither can they seize film or video tape from a photojournalist
after an event has occurred.
A 1989 case in Des Moines, Iowa found that police improperly seized
video tape from an individual who had recorded a street fight
where a man was fatally stabbed.
The photographer was an amateur who was not employed by any news
organization. He was in the 'downtown loop' area intending to
photograph and later sell any newsworthy footage to various local
television stations. He saw a fight going on, and videotaped the
stabbing. After police arrived, he informed them he had recorded
the crime, and the police seized the tape as evidence. Lambert
said the police repeatedly assured him he would be provided a
copy of the tape, and police never produced a search warrant for
the evidence. After the victim died that same day, police informed
Lambert he would not get his tape back, or a copy of it. That
same day Lambert reached agreement to sell the tape to a local
television station, and the station joined in the suit to get
the tape back.
The decision, handed down just 30 days after the event by the
Federal Judge for the Southern District of Iowa has several interesting
points.
First, he states that Lambert need not be a professional photojournalist
"It is not just news organizations, such as WHO-TV, that
have First Amendment rights to make and display videotapes of
events--all of us, including Lambert, have that right."
In addition, "There is clearly a threat of irreparable harm
to Lambert if he does not promptly get his videotape back. Lambert
has a right to use the tape under the United States Constitution.
. . . Defendants' refusal to provide him with a copy of the tape
threatens him with irreparable harm, which increases with each
passing day."
Judge Vietor states that, "Government cannot unlawfully seize
property of a citizen in violation of his basic constitutional
rights, and then continue the violation by not returning the property.
. . . Prior restraint rarely can be accommodated by the Constitution."
Judge Vietor has made the complete argument that for governmental
officials to prevent the publication of visual images is unconstitutional
prior restraint.
If officials cannot seize film and video tape after it is shot,
they also cannot physically prevent news photographers from doing
their job.
WSB-TV in Atlanta ran a series of stories in 1988 on allegations
that a sheriff had used inmate labor on private construction projects.
A physical altercation later resulted between the sheriff and
the reporter and cameraman. Most of the decision revolved around
the precise rules governing summary judgement, but the last paragraph
summed up the issue of restraining newsgathering:
". . . The November 6th incident was but one episode in the ongoing effort of defendant to thwart or impede plaintiffs in gathering and reporting news relating to rumors of the sheriff's use of inmate labor on his private property, an interference with plaintiffs' first amendment rights which would violate 42 U.S.C. sec. 1893."
There are many instances reported in News Photographer magazine,
and told by individual photojournalists where police officials
have detained photographers for a time, until an event is over,
and then released them without charges. Other times police or
fire officials have stood in the way, placed hands over lenses,
or physical restrained photographers from shooting scenes or events.
Clearly, this is an impermissible activity.
Much of the preceding evidence affects news photography by inference--since
photojournalism is part of journalism, news photography is also
included. A number of cases exist where courts have expressly
ruled on the rights of photographers to gather the news.
Schnell v. Chicago was a class action suit by a group of photojournalists
who covered the 1968 Democratic convention in Chicago. Officers
of the Chicago police department interfered with photographers
covering riots in ways ranging from holding them for several hours
in the back of squad cars to smashing their cameras and beating
them with batons. The seventh circuit court held that,
"There can be no conclusion but that the complaint sufficiently alleges that constitutionally protected activity was and continues to be interfered with by the named defendants and that the defendants have the duty and power to prevent any future interference."
In addition to the interference, the court said that singling
out photographers is likewise not permissible, stating that there
is "no meaningful difference between news photographers as
a class and news media personnel."
Connell v Hudson involved a photographer for a local paper covering
a traffic accident in Hudson, New Hampshire. He was forced to
move several times under orders from a police officer, finally
being literally run off of the street under the officer's harassment.
Connell ended up shooting his photos from the second story of
a house, with the owner's permission. He was spotted in the window,
and ordered not to photograph the scene and to leave the building.
When he refused, he was arrested for disturbing the peace.
The U.S. District court was clear in it's conclusion,
". . . The Court declares that David Connell's rights, protected from government intrusion by the First Amendment to the United States Constitution, were violated by the Town of Hudson police when they ordered him to stop taking pictures from positions that did not interfere with police activity."
One of the key factors in these situations is the definition of
"interference with police activity." In many cases,
photographers can be arrested for an offenses such as Disobeying
a Lawful Order. In these cases, when a police officer tells a
photographer to do something, whether the order is legal, or even
reasonable, the photographer can be arrested for even questioning
the order--a classic Catch 22.
This was the case in Leiserson v. San Diego when a passenger jet
crashed and a television photographer was found filming the crash
site. He was ordered to leave the site, and was pursued and removed
to a location where he could not view the crash location. In an
attempt to get back to the crash, he was arrested for failure
to obey a lawful order of a police officer. The interesting point,
and one that was ignored by the trial judge, was that in California
news photographers are granted expanded access to crash scenes
by statute.
The judge dismissed this argument by saying that the police officers
could not be expected to be knowledgeable about an obscure provision
in the law. The photographer did not obey the order of the officer
because he believed it, rightly, to be not lawful. While the photographer
was correct, he was still convicted.
Much the same case was found in State v. Lashinsky, a case in
New Jersey where the photographer was arrested and convicted with
interfering with a police officer. The conviction was upheld on
appeal, but in a stinging dissent Justice Pashman of the New Jersey
Supreme Court grabbed the issue by the horns.
"The majority emphasizes that defendant became embroiled in a heated exchange with Herkloz [the police officer] which both directly and indirectly interfered with the carrying out of Herkloz's duties. . . ."
What the majority fails to emphasize, however, is that the argument
erupted after and as a direct result of Herkloz's order that defendant
move on. A command that is unreasonable when uttered does
not become reasonable simply because a newsman will not abide
by its terms. . . . In effect, the majority has ruled that a newsman
acts illegally if he stands up for his rights and refuses to accede
to an arbitrary, and hence, unlawful, request." [Emphasis
in original]
We have seen that it is clear that newsgathering is protected,
to some degree, by the constitution. In addition, governmental
officials cannot restrict the type or method of newsgathering,
nor can they restrain photographers if they have been properly
admitted at a location or seize their film after the fact. It
has also been held for some time that the loss of First Amendment
freedoms results in "irreparable injury" to an individual,
whether professional or amateur.
This leaves us with a problem. If the outlines of the problem
are known, and the law is reasonably settled, why is there still
such a problem with governmental interference in photographic
newsgathering, and what can be done about it?
Michael Sherer, who teaches in the Department of Communication
at the University of Nebraska at Omaha, has published a paper
outlining a method using the federal civil rights statute 42 U.S.
Code section 1983 to force governmental agencies to respect the
First Amendment rights of photojournalists. This section of the
code was previously cited in the WSB-TV opinion. Under this section,
two essential elements must be present:
"(1) whether the conduct complained of was committed by a person acting under color of state law; and (2) whether this conduct deprived a person of rights, privileges, or immunities secured by the Constitution or laws of the United States."
The first consideration, acting under color of state law, is easy
to meet in most cases of overbroad restrictions. The media is
controlled by well established criminal and civil laws when dealing
with members of the public. Areas such as trespass and libel have
established histories, and these are not areas where prior restraint
questions apply. The major problem with restrictions leading to
prior restraint enter when photographers are dealing with breaking
news or government bodies. In these cases, the people preventing
newsgathering and, by extension, publishing, are officials of
government, therefore acting under "color of state law."
We have seen where newsgathering, and by extension, news photography,
has a limited constitutional protection, and several of the cases
previously cited have specifically mentioned the First Amendment
rights of journalists being abridged.
The press should become more active in educating law enforcement
personnel on the topics we've discussed. I'm not optimistic that
this education will be accepted. A secondary form of education
is for courts to protect and apply these rights when they have
been violated. Chiefs of Police and City Managers will educate
their people when courts have brought judgements against them.
Sherer sums it up best:
". . . photographic newsgathering must take place at the scene of breaking news events. Without a right of photographic access, there will be no visual record.
"Getting to the scene of a breaking news story presents a myriad of problems for the news photographer, not the least of which is convincing law enforcement officials of the value of granting news photographers reasonable access to these events. Any means within the law,including using the law itself to help promote and protect a news photographer's right of reasonable access to a newsworthy event, should be considered."
Unfortunately, it will not do a photographer any good to be standing
nose-to-nose with a state trooper while an airplane burns over
a hill, and try to describe the nuances of constitutional theory
and practice. Action on educating governmental officials must
be a constant, unrelenting process if photographic access to newsworthy
events is to be protected.
Photographs can define events, shape attitudes, and provide a
collective memory. But only if someone is there to take them.
Borreca v. Fasi 369 F.Supp. 906
Branzburg v. Hayes 408 U.S. 665
City of Oak Creek v. Ah King 436 N.W. 2d 285
Connell v. Town of Hudson 733 F.Supp. 465
Elrod, et al. v. Burns et al. 427 U.S. 347
Lambert v. Polk County, Iowa 723 F.Supp. 128
Leiserson v. City of San Diego 229 Cal. Rptr. 22
Near v. Minnesota 283 U.S.697
Quad-City Community News Service v. Jebens 324 F.Supp. 8
Richmond Newspapers v. Virginia 448 U.S. 555
Schnell v. City of Chicago 407 F.2d 1084
State of New Jersey v. Lashinsky 404 A.2d 1121
WSB-TV v. Lee 842 F.2d 1266
Associated Press Story. "AM-Armed Cult" April 21, 1993
Associated Press Story. "XGR-Camera Ban" February 11, 1993
Bazin, Andre'. "The Ontology of the Photographic Image" The Camera Viewed: Writings on Twentieth-Century Photography. New York: E.P. Dutton. 1979
Becker, Karen E. "To Control Our Image: Photojournalists and New Technology" Media, Culture and Society. July, 1991
Boot, William. "Covering the Gulf War: The Press Stands Alone" Columbia Journalism Review. March/April, 1991
Boylan, James. "How Free is the Press?" Columbia Journalism Review. September/October, 1987
Cartier-Bresson, Henri. "Introduction to the Decisive Moment (1952)" The Camera Viewed: Writings on Twentieth-Century Photography. New York: E.P. Dutton. 1979
Dow, Caroline. "Prior Restraint on Photojournalists" Journalism Quarterly. Spring, 1987
Evans, Harold. "I, Witness" American Photographer. January, 1992
Frost, Dan. "Death Watch, Should TV Cover the Gas Chamber" Columbia Journalism Review. March/April, 1991
Hirsch, Mark. Interview With Chief Photographer of the Dubuque Telegraph-Herald. April 20, 1993
Iorito, Sharon. "How State Open Meeting Laws Now Compare With Those of 1974" Journalism Quarterly. 1986
Kaplan, Davad A. "Live, From San Quenton . . ." Newsweek. April 1, 1991
Klerman, David. "Is the Military Throttling the Media?" USA Today. January, 1991
Koch, Adrienne and Peden, William. The Life and Selected Writings of Thomas Jefferson. New York: Random House. 1944
Newhall, Beaumont. The History of Photography. New York: The Mueseum of Modern Art. 1981
News Photographer Magazine. Issues from 1988 through 1993
Sherer, Michael D. "A survey of Photojournalists and Their Encounters with the Law" Journalism Quarterly. Summer/Autumn, 1987
Sherer, Michael D. "Civil Rights Protection for Photographic Newsgathering" Communications and the Law. September, 1991
Sherer, Michael D. "The Problem of Trespass For Photojournalists" Journalism Quarterly. Spring, 1985
Steichen, Edward. "Photography: Witness and Recorder of Humanity (1958)" The Camera Viewed: Writings on Twentieth Century Photography. New York: E.P. Dutton. 1979
Street, Richard Steven. "The Battle of Salinas: San Francisco Bay Area Press Photographers and the Salinas Valley Lettuce Strike of 1936" Journal of the West. April, 1987.
Teeter, Dwight L. "The First Ammendment at Its Bicentennial: Necessary But Not Suffcient?" Journalism Quarterly. Spring, 1992
Thompson, Mark. "With the Press Pool in the Persian Gulf" Columbia Journalism Review. November/December, 1987
Webster's Clear Type Dictionary. Nashville: Thomas Nelson. 1976
Webster's New Universal Unabridged Dictionary. New York: Simon
& Schuster. 1979
Endnotes