Transgender Day of Remembrance

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Transgender Day of Remembrance (also known as Trans Day of Remembrance, or TDoR) is observed annually on November 20 to memorialize and honour trans victims of murder and violence. The goal of the movement is to draw attention to the violence enacted against trans, gender-diverse and two-spirit people globally; many of the events focus on the emotional trauma of being a victim of violence and building solidarity across a community that suffers from that violence to a great extent. TDoR, thus, is a movement that prioritizes mourning and healing over concrete affirmative action. TDoR was founded in 1999 following the death of Rita Hester, a San Fransisco transgender woman, and has since grown to include vigils, sit-ins and protest marches each year, on the day. The movement also aims to bring tragically high global trans murder rates to light by gathering statistics and encouraging policy change such as legal trans protection and sufficient monitoring of trans-related hate crime statistics. The latest TDoR update reveals a total of 2,264 trans people have been murdered in 68 countries globally between 2008 and 2016 [1].

The Movement

The Trans Day of Remembrance movement is a protest for vigilance and justice. Too often, trans murder cases go unsolved, and even when the perpetrator is known and apprehended, the criminal justice system may “victim blame”, absolving the perpetrator for their crimes under the guise that the trans victim was somehow deserving of the violence enacted against them. The day is a collective movement to respond to the cis-sexism and transphobia which exist in many, if not most, cultures, and the ensuing violence and injustice. It also has been used as a way to demand accountability from authorities and the various institutions meant to protect trans people. The Trans Day Of Remembrance movement offers a place for outrage and a safe and empowering community for the most vulnerable populations (specifically transgender women of colour). It also creates a space to empower people to live their authentic lives and show love and support. Trans Day of Remembrance emphasizes the building of networks, particularly through social media, to expand their presence to a global scale.

Trans Youth, Violence and Suicide

Trans youth are particularly vulnerable to violence, both self-harm and perpetrated by others, due to their lack of independence from harmful familial or community relationships, and the social and legal restriction placed upon their self-determination. A recent study of trans youth in Canada noted that 65 percent of younger youth had attempted suicide in the past twelve months, and “almost three-quarters of older youth had seriously considered suicide at some point during their lives” [2] In 2014 the Huffington post reported on findings released by the Transgender Violence Tracking Portal which concluded that, according to data collected across 36 countries, 10 percent of trans people who had been murdered that year had been youth under the age of nineteen [3]

Trans Day of Remembrance works to raise awareness of the specific issues faced by trans youth through the memorialization of young people who have been murdered or who have taken their own lives. Some of these issues include: non-acceptance and rejection from family and community; lack of guardian support in seeking gender-affirming medical care; religious or cultural repression, including conversion therapies; poverty and exclusion from community resources; and cis-sexist and transphobic violence.

Sadly, in the wake of the US presidential election, the number of calls to trans-suicide helplines has reportedly spiked. Twenty-four hours after the election, Guardian reporter James Stafford released a tweet alleging that “at least 8 trans youth [had] committed suicide in the wake of Trump’s win” [4] In these catastrophic times, it is imperative that we rally around movements such as Trans Day of Remembrance which are actively resisting oppression, marginalization, and violence against trans youth. #TDoR

Violence Against Trans Identities by the Police, Correctional and Judicial Systems

Trans Day of Remembrance helps draw attention to the violence perpetrated by law enforcement, correctional, and judicial systems, and raises awareness of the danger trans people often face in interacting with these institutions. Violence against trans people by police is not uncommon. In Ontario, one study found that 24 percent of trans people had experienced harassment by police.[5] On February 4th, 2016, “a 24-year-old Kayden Clarke, a transgender man from Arizona, was shot and killed by police in his home”.[6] Similarly, the case of Brooke Fantelli, a transwoman who was repeatedly tasered by a ranger, after the ranger learned that she was trans, provides yet another example of police violence against the trans community.[7] According to Emma Caterine’s article on justice for the murder of trans people, in countries like Brazil and Jamaica the trans community is particularly at risk because “trans people are often killed by police officers themselves”.[8] Trans Day of Remembrance memorializes the victims of these acts of violence and raises the issue of police abuse of trans populations in the media.

The lack of recognition of gender identity in the corrections system, the forcing of trans inmates to be incarcerated in prisons which align with their assigned gender, not their true gender-identity, represents another act of systemic violence against trans individuals. In 2015 this violence became tragically evident with the suicides on Joanne Latham and Vicky Thompson, two trans women who took their lives within a few weeks of one another after being incarcerated in male prisons on Britain.[9] In São Paulo in 2015, Verônica Bolina, a transwoman incarcerated in a men’s prison was stripped, brutally beaten, and had her head shaved by Brazilian police, in an act of transphobic violence enacted by state correctional authorities.[10]

Anti-Trans violence in the judicial system is especially prominent in the light sentencing of perpetrators of murder and violence against transgender people, particularly through the practice of ‘panic’ defences which remain permissible tools of court-defence in most of the world:[11]

Gay and trans “panic” defense tactics ask a jury to find that a victim’s sexual orientation or gender identity is to blame for the defendant’s excessively violent reaction. The perpetrator claims that the victim’s sexual orientation or gender identity not only explain – but excuse – their loss of self-control and subsequent assault of an LGBT individual. By fully or partially acquitting the perpetrators of crimes against LGBT victims [12]

A prominent example of such a defense used to sanction injustice was in the trial of three young men accused of beating seventeen-year old Gwen Araujo to death in 2003. The three accused’s charges were downgraded to second degree murder after a mistrial sparked by the argument that the homicide was committed out of an emotional panic upon learning that Araujo was trans.[13] Due in part to the advocacy work of movements such as Trans Day of Remembrance, such panic defenses have begun to come under criticism in the US, with California becoming the first state to successfully ban the panic defense in 2014: a small victory against such egregious and violent misuses of the judicial system.[14]

Transgender Day of Remembrance continues to build solidarity across the trans community in resisting these institutionalized perpetrations of violence against trans and gender-diverse bodies. While the aspirations of the movement are not political or lobby-oriented, the existence of the vigil serves to promote demands for justice and accountability in police, correctional, and judicial frameworks internationally.

Global Legal Context of LGBTQ+ Protection

The legal system regarding LGBTQ+ people vary across the globe. Statistics show the correlation between richness of the country and its likeliness to pass the laws granting LGBTQ+ rights. Most Western country and some South American countries have evolved the LGBTQ+ rights protection law, while many countries in Africa still maintain anti-LGBT law which are colonial legacies and most of the countries with Muslim majority have severe anti-LGBT legal system [15].

Green zone shows the regal recognition of LGBT rights while red zone shows the criminalization of same-sex relations.

As the map shows, same-sex relations are criminalized in at least 73 countries. In Middle Eastern countries such as Sudan, Iran, Saudi Arabia and Yemen, same-sex relations are considered to be liable to imprisonment or death penalty under Shari'a. In Iraq, both police and militias have frequently kidnapped, threatened and killed LGBT people [16]. There is an anti-LGBT tendency in Russia. The Government has intimidated and arrested LGBT activists in recent years and introduced the new law in 2013 which sets administrative fines for public affirmations of “non-traditional sexual relations” [17].

Seen from global perspective, however, we can say that state-led anti-LGBTQ+ violence is diminishing as the number of countries that criminalize same-sex relations has declined dramatically (92 countries in 2006 has changed to 73 in 10 years[18]. Also, a number of countries, including many in the global South, have adopted legal provisions that prohibit sexual orientation discrimination nationwide[19] . Nevertheless, it is true that we cannot judge the condition of rights of LGBT people by laws alone. Research results show that even in countries such as South Africa, Brazil and the United States, which have some of the best legal protections in the world face more violence than non-LGBT people [20].

There is an international attempt to combat Anti-LGBT violence. The Yogyakarta Principles, for example, intends to condemn not only state-led violence against sexual minority but also extra-judicial killings, torture, ill-treatment and discrimination against LGBT population and urges nations the importance of protecting human tights of LGBT people referring relevant international human rights law[21]. Also, In such countries such as India, Kenya, and Lebanon, where same-sex sexual activity and gender non-conformity are criminalized, vibrant social movements have emerged and improved the quality of life for LGBT people[22].

Successes and Challenges

Successes

Transgender Day of Remembrance (TDOR) has many successes in the areas of Human Rights Legislation, creating a grassroots vehicle for building an international community linked through its website and vigils as well as creating global awareness of those lost to transgender violence in countries all over the world. These successes are more commonly related to the LGBQT rights movement as a whole, but TDOR’s part in raising awareness is tantamount in further LGBQT rights discourse. Without statistical data collected by TDOR since it’s inception in 1998 [23], many of the legislative changes and societal awareness may not have come to fruition. TDOR is a vehicle for change and this has become apparent, as LGBQT rights have moved to the forefront of international discourses on Human Rights [24]. While its influence may not be documented as having a direct correlation to these changes, it is part of the broader movement influencing global change towards the transgender community.

International Successes

The Transgender Day of Remembrance is responsible for raising public awareness of transphobic crimes, an action the media does not accurately describe in it's coverage of homicides involves transgendered people, TDOR website actively compiled statistical data on transphobic crimes since it's inception up to 2012[25], whereafter the FBI began compiling statistics on crimes against transgendered individuals [26], and it also offers a vehicle for communication between communities all across the globe which helps build solidarity [27].

ŸTDOR has also helped influence the creation of other organizations that fight for LGBQT+ rights such as “ADD THE WORDS (ATW), IDAHO” which is a volunteer run organization focused on updating the existing Idaho Human Rights Act (IHRA) to add "sexual orientation" and "gender identity" [28]. Another example is the creation of International Day against Homophobia, Transphobia and Biphobia in 2004, which is now celebrated on over 130 countries, 37 of which were same-sex acts are illegal. It is recognized by several states, international institutions such as the European Parliament and the United Nations recognizing this day with events as well [29].

Legislation

Successes learned from course readings and lectures include the success of ‘Human rights framing’ of LGBT has enabled groups to influence the scope of legislation in the European Union (EU) and even the UN, gaining more rights for LGBQT members, although not perfect, this is a step in the right direction [30]. "These international developments have reflected in domestic political settings, as is illustrated by the adoption of same-sex union policies by a majority of Western democracies over the past two decades" [31]. Also influenced by movements such as TDOR are the creation of 2 major documents: the Declaration of Montreal (International Conference on LGBT Human Rights 2006) and the Yogyakarta Principles on the Application of International Human Rights Law in Relation to Sexual Orientation and Gender Identity [32].

Global Awareness

International collaboration has been a cornerstone in promoting TDOR as a global movement, not simply one relegated to North America. After its origin in the United States, TDOR now stands as a globally recognised day of remembrance; as of 2016, TDOR is observed in more than 180 cities in over 20 countries within North America, Europe, Asia, Africa and Oceania [33].

TDOR first found global roots within Europe through the establishment of Transgender Europe (abbreviated as TGEU), which followed the first European Transgender Council in Vienna in November of 2005. The organisation - which was formally recognised as both a charitable organisation and a legislative vehicle by the Austrian government in early 2006 - is a combination of a volunteer and advocacy organisation, and is now considered to be the legitimate voice of the trans community within Europe [34].TGEU has lobbied effectively for legislative change within multiple European countries, through advocacy efforts within the Council of Europe and the European Court of Human Rights. As of 2016, TGEU has formed offices in Vienna, Berlin, Budapest and Dublin, all of which speak to the strength of the TGEU and its role in fostering a global approach to combating transphobia and trans-violence [35].

The limited collection and distribution of data regarding transphobia and trans-violence has affected the breadth of change enacted by TDOR; within most countries, statistics pertaining to violence against trans or gender-diverse persons is largely unavailable, which hinders both awareness and the possibility of change to take place [36]. Arguably, the largest accomplishment of the TGEU has been the formation of the Trans Murder Monitoring (TMM) project, which began in April of 2009, and systematically monitors, collects, and analyses reports of homicides of trans and gender-diverse people worldwide [37]. These results are presented three to four times a year, and pertain to all globally reported cases of transphobia and trans-violence. According to the TMM, the close connection between the existence of strong trans movements and professional monitoring, alongside the publication of the highest absolute numbers of reports, lead to two contrasting conclusions: first, that stronger monitoring has allowed for a growth in global awareness and change, and secondly, that the continued estimate of unreported cases speaks to the need for further professional monitoring and reporting of violence against trans and gender-diverse peoples.

Organisations such as TGEU have allowed for piecemeal change to occur within the European Union regarding the treatment of trans and gender-diverse persons; for example, England and Spain have passed laws that allow for individuals to change their gender on official documents, in 2004 and 2007 respectively [38]. This change has also slowly began to migrate to Latin America, whereupon countries such as Uruguay, Argentina and Colombia have passed similar laws regarding gender-identity and expression. Change within Latin America regarding trans-rights and trans-respect can be attributed to the growing number of advocacy organisations throughout Latin America. Two such organisations of note are Aquelarre Trans and Dejusticia, both of which are Colombian groups of lawyers and trans-activists, with offices within Bogota and Buenos Aires, who advocate and raise awareness of trans-violence within Latin America [39]. Their original aim was to re-create gender identity laws within Argentina and Colombia - which was accomplished in 2013 - and who now focus on raising activism within Latin America. The success of both Aquelarre Trans and Dejusticia is not limited to solely legislative change, but also educational change; these groups have directly led to the formation of the Action Program for Equality and Social Inclusion at the University of Los Andes School of Law, the first program within a Latin American university that focuses on trans-rights.

Challenges

Ilga sexual orientation laws in the world overview
TMM update Trans Day of Remembrance 2016

TDOR has been met with challenges from outside the community and from within the LGBQT community itself. Challenges in the past included the collection of statistics; which was predominantly collected through media outlets and as such were not always clear whether or not the homicide was because of transgender hate or because of classism [40]. This is also coupled with the emotional stresses that individuals compiling this information faced. [41]. Within the community the claiming of victims by groups aligned as being Gay, Lesbian, Intersex or Transgender has hindered the compilation of TDOR’s statistics and also leads to internal turmoil [42]. Lastly data from countries who do not recognize transgender communities and criminalize such acts have no statistical data related to these hate crimes as in some instances it is punishable by death [43].

Organizational Challenges

The same issues that many grassroots organizations face is relevant to TDOR, finding funding, organizing and staying true to those they are memorializing are some challenges to name a few [44]. Also each even is run by different individuals so the vigils are run will vary greatly from state to state, city to city, in some instances these vigils can be met with more violence, in other little to no recognition by greater society, making it's effectiveness in spreading its message difficult to gauge [45].

Challenges Within LGBQT Community

Challenges also exist within the LGBQT+ community concerning TDOR and "claiming of victims". Different communities whether it be transgender, gay, lesbian, transexual each attempt at claiming victims of violence as their own; examples can be seen in the Brandon Teena case; who was murdered in 1993 and was considered a simple sexual assault case by journalists who ignored his sexual identity at times referring to him as her [46] which sparked fierce battles among transgender, transexual, and lesbian and gay activists who each wanted to claim his murder attack as their own [47]. Another example is found in the murder of Deanna/Thomas Wilkinson and Shawn Keegan who were identified as cross dressers and victims of transgender violence on Remembering our Dead (TDOR's sister site) yet also included in Douglas Janoff’s inventory of homophobic violence in Canada in 2005 [48]. Namaste maintained these deaths were due to anti-prostitution and class-based discrimination, based on the perpetrator describing street people and prostitutes as scum and demonstrated clear evidence of transphobia[49][50].

Areas for Improvement

Areas for improvement in this type of movement are difficult to pinpoint as there is a great deal of interconnectedness between groups and organizations both domestic and international, governmental, political and grassroots. The underlying stream found through out this entire research project has been that of creating community, and finding solidarity across communities. If anything should be the focus of improvement is it not on the TDOR movement itself, but on the education of all communities regarding hate crimes, especially homicides due to discrimination and hate of particular groups.

While extraordinary steps have been taken in protecting rights of LGBQT+ people since the inception of TDOR in 1998, these is still much work to do and enforcement from the top down has proved difficult in even the best circumstances for 1st world countries such as Canada who fail to uphold their agreement on Human Rights [51].

References

  1. ↑ Transgender Europe. TDoR 2016 press release. http://tgeu.org/tdor-2016-press-release/ Acessed November 20 2016
  2. ↑ Veale J, Saewyc E, Frohard-Dourlent H, Dobson S, Clark B & the Canadian Trans Youth Health Survey Research Group (2015). Being Safe, Being Me: Results of the Canadian Trans Youth Health Survey. Vancouver, BC: Stigma and Resilience Among Vulnerable Youth Centre, School of Nursing, University of British Columbia.
  3. ↑ Walkley, A.J. "2014 Transgender Violence Statistics Sobering Thus Far." The Huffington Post. TheHuffingtonPost.com, 05 Dec. 2014. Web. 10 Nov. 2016.
  4. ↑ Preston, Dominic. "Reports Claim 'at Least 8' Trans Youth Died by Suicide After Trump's Win." Pink News. N.p., 10 Nov. 2016. Web. 12 Nov. 2016.
  5. ↑ Bauer, Greta R., and Ayden I. Scheim. "Transgender People in Ontario, Canada: Statistics from the Trans PULSE Project to Inform Human Rights Policy." Trans PULSE Project (2015): 1-8. TransPulseProject.ca. Web. 16 Nov. 2016.
  6. ↑ "Violence Against the Transgender Community in 2016." Human Rights Campaign. HRC, 2016. Web. 15 Nov. 2016.
  7. ↑ Wong, Curtis M. "Brooke Fantelli, California Transgender Woman, Allegedly Tased In The Crotch By Imperial County Desert Rangers." The Huffington Post. TheHuffingtonPost.com, 12 Apr. 2011. Web. 18 Nov. 2016.
  8. ↑ Caterine, Emma. "How the Trans Murder Spectacle Perpetuates Myths About Justice." Truth Out. N.p., 13 Apr. 2016. Web. 16 Nov. 2016.
  9. ↑ Allison, Eric, and Helen Pidd. "Second Transgender Prisoner Found Dead in Male Jail." The Guardian. Guardian News and Media, 01 Dec. 2015. Web. 12 Nov. 2016.
  10. ↑ Malone, Luke. "Beating Of Transgender Prisoner Causes Outrage In Brazil." Vocativ. N.p., 20 Apr. 2015. Web. 12 Nov. 2016.
  11. ↑ Lee, Cynthia, and Peter Kar Yu Kwan. "The Trans Panic Defense: Heteronormativity, and the Murder of Transgender Women." Hastings Law Journal 66.77 (2014): 77-132. Social Science Research Network. Web. 18 Nov. 2016.
  12. ↑ "Gay and Trans Panic Defense." The National LGBT Bar Association. N.p., 2015. Web. 20 Nov. 2016.
  13. ↑ Lee, Cynthia, and Peter Kar Yu Kwan. "The Trans Panic Defense: Heteronormativity, and the Murder of Transgender Women." Hastings Law Journal 66.77 (2014): 77-132. Social Science Research Network. Web. 18 Nov. 2016.
  14. ↑ Molloy, Parker Marie. "California Becomes First State to Ban Gay, Trans 'Panic' Defenses." Advocate. Advocate.com, 29 Sept. 2014. Web. 16 Nov. 2016.
  15. ↑ Nunez, Christina. “Map Shows Where Being LGBT Can Be Punishable by Law.” National Geographic. 16 June. 2016. Web. 12 Nov. 2016.
  16. ↑ Nunez, Christina. “Map Shows Where Being LGBT Can Be Punishable by Law.” National Geographic. 16 June. 2016. Web. 12 Nov. 2016.
  17. ↑ The Council for Global Equality. “The Facts on LGBT Rights in Russia” Web. 12 Nov. 2016.
  18. ↑ United Nations. “The History of the Right to Love (if You’re Gay).” Web. 12 Nov. 2016.
  19. ↑ Kollman, Kelly, and Matthew Waites. "The global politics of lesbian, gay, bisexual and transgender human rights: an introduction." Contemporary Politics 15.1 (2009): 1-17.
  20. ↑ Carroll, Aengus “State-Sponsored Homophobia.” ILGA. Oct. 2016.
  21. ↑ The Yogyakarta Principles at http://www.yogyakartaprinciples.org
  22. ↑ Carroll, Aengus “State-Sponsored Homophobia.” ILGA. Oct. 2016.
  23. ↑ http://tdor.info
  24. ↑ Kollman, Kelly, and Matthew Waites. "The global politics of lesbian, gay, bisexual and transgender human rights: an introduction." Contemporary Politics 15.1 (2009): 1-17. http://www.tandfonline.com/doi/pdf/10.1080/13569770802674188?needAccess=true
  25. ↑ https://web.archive.org/web/20120409032158/http://www.rememberingourdead.org/day/what.html
  26. ↑ https://ucr.fbi.gov/hate-crime/2015/resource-pages/abouthatecrime_final
  27. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of Califonia
  28. ↑ http://www.addthewords.org
  29. ↑ http://dayagainsthomophobia.org
  30. ↑ Kollman, Kelly, and Matthew Waites. "The global politics of lesbian, gay, bisexual and transgender human rights: an introduction." Contemporary Politics 15.1 (2009): 1-17. http://www.tandfonline.com/doi/pdf/10.1080/13569770802674188?needAccess=true
  31. ↑ Kollman, Kelly, and Matthew Waites. "The global politics of lesbian, gay, bisexual and transgender human rights: an introduction." Contemporary Politics 15.1 (2009): 1-17. http://www.tandfonline.com/doi/pdf/10.1080/13569770802674188?needAccess=true
  32. ↑ Kollman, Kelly, and Matthew Waites. "The global politics of lesbian, gay, bisexual and transgender human rights: an introduction." Contemporary Politics 15.1 (2009): 1-17. http://www.tandfonline.com/doi/pdf/10.1080/13569770802674188?needAccess=true
  33. ↑ http://tgeu.org/about/
  34. ↑ http://tgeu.org/our-work/
  35. ↑ http://tgeu.org/our-work/our-global-work/
  36. ↑ http://tgeu.org/our-work/our-global-work/tvt/
  37. ↑ http://tgeu.org/tag/trans-murder-monitoring/
  38. ↑ http://tgeu.org/tgeu-media-statement-council-of-europe-adopts-historic-transgender-resolution/
  39. ↑ http://www.newyorker.com/news/news-desk/latin-americas-transgender-rights-leadership
  40. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of California
  41. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of California
  42. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of California
  43. ↑ TvT research project (2016). Trans Murder Monitoring, “Transrespect versus Transphobia Worldwide” (TvT) project website: www.transrespect.org/en/research/trans-murder-monitoring/ http://transrespect.org/wp-content/uploads/2016/05/TvT_TMM_IDAHOT2016_Map_EN.pdf
  44. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of California
  45. ↑ http://tdor.info/FAQ
  46. ↑ http://www.glaad.org/2011/05/05/telling-brandon-teenas-story-accurately
  47. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of California
  48. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of California
  49. ↑ Namaste, V. (2000). Invisible Lives: The erasure of trans-sexual and transgender people. Chicago: University of Chicago Press.
  50. ↑ Lamble, Sarah. (2008) Sexuality Research and Social Policy: “Retelling Racialized Violence, Remaking White Oppression: The Politics of Interlocking Oppressions in Transgender Day of Remembrance.” The National Sexuality Research Centre, University of California
  51. ↑ https://www.thestar.com/news/canada/2015/07/23/anti-terror-bill-not-in-keeping-with-canadas-international-obligations-un.html
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