If you believe Newt Gingrich, sharia is a mortal threat to Western civilization and to American rule of law because “stealth jihadists” are manipulating our legal system so sharia can creep in, slowly and steadily eroding our secular laws until sharia has overtaken the Constitution as the supreme law of the land.1 The Republican presidential hopeful is not the only one to warn of the threat of “creeping sharia” in the United States. Several conservative politicians, bloggers and commentators2argue that sharia, not violent jihad, is America’s wartime enemy since 9/11 and that the fight against it is “the civil rights struggle of the 21st century.”3 Their solution? A pre-emptive strike against sharia before it is too late: We should enact state and federal legislation to ban consideration of sharia in all American courtrooms. The most aggressive version of this project was launched last year in Tennessee, where a state senate bill defined sharia as a legal-political-military doctrine that “requires the abrogation, destruction, or violation of the United States and Tennessee Constitutions and the imposition of sharia through violence and criminal activity,”4 and would have made it a felony to support any state-designated sharia organization.5 After public opposition, the sharia references were removed from the bill, but the “sharia threat” remains a live issue in Tennessee. A different (and somewhat more successful) approach was taken in 2010 in Oklahoma, where voters overwhelmingly passed the “Save Our State” amendment prohibiting Oklahoma courts from considering international law or sharia law.6 That amendment is currently suspended, pending federal appeal on constitutional grounds. But the anti-sharia campaign continues with missionary zeal. The latest version is called American Laws for American Courts (ALAC), which does not specifically prohibit sharia per se, but sharia is clearly its primary target.7 At this point, more than a dozen states have proposed, and many have passed, legislation following either the Oklahoma or ALAC model, and it is expected that many more will do so as we near the presidential election this year. Fueled by the still-persistent myth that President Barack Obama is a Muslim, many Americans casting their vote in November will likely also be asked whether their state should ban sharia.8
But most Americans know nothing about what they are being asked to ban, nor enough about how judges currently treat sharia-based claims to know whether a ban is even needed in the first place. Anti-sharia advocates insist that naive liberal judges are compromising American law in favor of sharia such that if the bans are not instituted soon, Americans will discover too late that we have let in a sharia Trojan horse that will ultimately take over our country. The cases they cite as evidence of this sharia infiltration do not actually illustrate this phenomenon – several are actually examples of judicialrejection of sharia-based claims9 – but concerns about sharia have nevertheless found a solid place in American politics. There is now enough fear of a sharia threat that candidates seem to gain political points by opposing sharia and distancing themselves from Muslims in general.10 Some Americans believe that we should be suspicious of Muslims in public office.11 Congressman Keith Ellison, the first Muslim elected to Congress, and New Jersey Superior Court Judge Sohail Mohammed are just two examples of American Muslims whose loyalties have been questioned because of their religion, with suggestions that they might be part of a stealth or civilizational jihad arm of the sharia conspiracy to take over the country. It all sounds like the plot of a (badly researched) Hollywood movie, but this is the reality of American politics today.
Even among Americans who are not convinced that sharia is the global political-military threat that Gingrich thinks it is, most have little that is positive to say about it. In American public discourse, sharia is most often associated with terrorism, oppression of women and harsh criminal laws, leaving very little room for Americans to imagine sharia as a positive force in Muslim lives. A decade ago, this might not have mattered much, but things are different now that sharia has been inserted into American politics. With American public discourse so heavily weighted against sharia in any form, few Americans have any appreciation for what sharia actually means for American Muslims or what a sharia ban would mean in practice. I believe there are several important and largely overlooked features of sharia and American law that reveal the anti-sharia campaign to be a destructive solution in search of a problem.
What sharia means to American Muslims
Are American Muslims living by sharia and raising sharia-based legal claims in American courtrooms? Yes, but not in a way that threatens American law. For an average Muslim, sharia means the rules by which one lives an Islamic life. Most common are the rules regarding ritual practice, morality and etiquette, as well as property ownership, business transactions, marriage and divorce, and inheritance. There are several different schools of Islamic law for Muslims to choose from (more on this later), so the actual rules that are followed vary greatly from person to person. Muslims in America also span the spectrum of religious observance, so sharia matters more to some than to others.
American courtrooms have seen several recurring sharia topics raised as legal issues. Many of these are requests for accommodation for religious dress, dietary rules and ritual practice, such as prayer and fasting. More complex cases involve sharia-based rules about business transactions, family law and inheritance. For example, many American Muslims follow Islamic rules prohibiting usury and highly speculative market transactions when making financial investments (including home-buying), and include reference to these rules in their contracts. Also, most Muslims marry according to sharia-based rules defining a valid Muslim marriage, which means that the required provision for a mahr (bridal gift) often becomes relevant in dissolutions of property upon divorce. Finally, many American Muslims take legal steps for their estate to be distributed according to Islamic inheritance rules instead of prevailing state intestacy law.
One important note: Muslims in the United States are decidedly uninterested in sharia criminal law. Contrary to insinuations from the anti-sharia campaign, Muslims in the United States show no interest in having American law criminalize actions such as extramarital sex or alcohol consumption, or punishing theft with hand amputation. Although some point to Iran, Saudi Arabia or Pakistan to suggest that Muslims desire state punishment of these crimes, these references are inappropriate for the context of Muslims living under a secular government like the United States. Simply put, the criminal laws of foreign Muslim countries say nothing about what laws American Muslims would like to enact in the United States, any more than the laws of the Jewish state of Israel tell us anything about what laws American Jews want enacted in America.
How religious legal claims are treated in American courts
The anti-sharia campaign argues that judicial accommodation of sharia-based requests represents a new threat to our secular American rule of law. But the task of protecting religious freedom within a secular legal system is a challenge that our nation has negotiated since its birth. American Jews, Catholics, Mormons, Sikhs, Hindus, Buddhists, Native Americans and others regularly request legal accommodation for religious rules that conflict with the secular law of the land. As a result, our legal system has established several policies and practices for adjudicating these cases. To put it concisely, American judges balance the constitutional right to religious exercise with other constitutional and legislative principles, using legal tools such as comity, public policy and unconscionability.12 Results vary depending upon the particular facts. Sometimes the religious request wins, sometimes it doesn’t. For example, Jewish yarmulkes are not exempted from military dress codes but accommodations are sometimes made in police departments; Amish children are not forced to comply with mandatory public schooling laws beyond the eighth grade; Catholic adoption agencies were not exempted from state laws prohibiting sexual orientation discrimination. None of these cases are easy, and reasonable minds differ over whether the courts get it right each time. But in every case, the job of the judge is a careful balancing of rights against each other, not an automatic trumping of religious practice by secular law or vice versa.
Sharia in American courtrooms
What does this balancing look like in cases involving sharia specifically? In criminal cases, sharia-based arguments are routinely outweighed by the secular law of the land. Not unlike similar claims from other religious minorities, American courts reject purportedly sharia-based defenses to excuse criminally prohibited acts such as domestic violence and child abuse.13 But the most common sharia-based claims involve issues of Islamic family law. Divorce cases dominate the field, with mahr being perhaps the most litigated issue. Muslim divorce cases are especially interesting because, in addition to religious freedom, they involve a secular freedom recognized by American law: freedom of contract. Because of the characteristically contractual nature of marriage in Islam, Muslim marriages generally include a written marriage contract detailing, among other things, what mahr (if any) is owed to the wife upon divorce. It is a longstanding principle in American law to give effect to the meeting of the minds of contracting parties, including their foreign choice of law, as long as its application is not outweighed by American public policy or constitutional principles. A choice of religious law by contractual reference is treated the same as foreign law – it is generally honored unless: (1) it violates basic contract law (for example, its terms are unclear), or (2) applying it would violate public policy.14
Sharia-based arguments that have been rejected for conflict with public policy include unilateral talaq (a Muslim husband’s unilateral access to no-fault divorce) because of its lack of due process and fair hearing given to the wife,15 and strictly gendered child-custody rules as they conflict with the “best interests of the child” standard, now prevailing in all states.16 Coercion is also fatal to enforcement of a contract term. American judges have declined to enforce mahr clauses if they conclude there was coercion or a lack of understanding by one of the parties.17
Accommodation of sharia does not threaten our rule of law; it is an illustration of it
These cases illustrate that American judges neither automatically reject nor automatically defer to sharia requests. Rather, these claims are judged against American public policy and other important principles of American law. In other words, once you actually look at the sharia-based requests that American Muslims are making, and how American judges actually treat them, it is blatantly – almost embarrassingly – obvious that there is no sharia threat. When American Muslims say they want to live their lives by sharia, they do not mean they want state enactment of sharia. Rather, they would sometimes like to opt out of the prevailing secular law for religious reasons. By making legal requests in American courtrooms, they are not forcing anyone else to opt out with them. (There is a fundamental difference, after all, between an opt out and a takeover.) And when judges accommodate these sharia-based opt-out requests, it is not an example of the slow creeping “shariazation” of American law, but rather of how religious freedom is protected in our secular country.
To see a sharia threat in these cases is simply to mistake religious freedom for religious invasion. It is to conflate the First Amendment’s Free Exercise Clause (protecting the free exercise of religion) with its Establishment Clause (prohibiting government establishment of religion). Despite anti-sharia commentary that sometimes slides these categories together, state protection of religious practice is not the same thing as state entanglement with religion. Judicial protection of American Muslims’ sharia-based practices does not mean America has begun to establish sharia as the law of the land (nor does it make us more vulnerable to terrorist attack). But it does demonstrate to ourselves and to the world that Americans value religious freedom and religious pluralism, and that we believe our nation is the better for it.
The project to redefine sharia
The only way judicial accommodation of sharia could signal the beginning of a sharia takeover is if sharia did not mean Islamic law at all, but rather, some sort of religious tyrannical movement. Redefining sharia along these lines is, in fact, the founding premise of the anti-sharia campaign, which depends upon the circular argument that begins with describing sharia as a Muslim totalitarian movement and then asserts that sharia must be prohibited because it is a threat to national security.18 As it turns out, the project to redefine sharia is more important even than banning it. As principal sharia-ban author David Yerushalmi himself recently revealed, “If this thing passed in every state without any friction, it would have not served its purpose. The purpose was heuristic – to get people asking this question, ‘What is Shariah?’ ”19
If changing the meaning of sharia is the major goal of the movement, then anti-sharia rhetoric in America may continue long after the 2012 election. This means that “what is sharia?” is a question that deserves time and attention by any American not quite convinced by the “global caliphate takeover” definition provided by anti-sharia advocates. There is neither time nor space for a full elaboration of “sharia” here, but I can summarize some key points important for all Americans to understand. Below are some basic concepts that can serve as a foundation for those interested in eventually answering the question for themselves.
What is Sharia?
- Sharia is the “recipe,” not the resultFirst, sharia is not “religious law” in the sense that most Americans are accustomed to thinking of religious law – i.e. a set code of divine legal rules. Instead, think of sharia as a recipe. There are, of course, fundamental differences between God and a cookbook author, but to understand sharia as it exists in the world, it helps to keep this metaphor in mind. Sharia is the way that Muslims believe God has advised people to live, as documented in the Quran and the practices of Prophet Muhammad. Literally meaning street, sharia refers to God’s Way or God’s Law, which practicing Muslims use as a guide for their lives. Sharia is, so to speak, the Muslim recipe for living a good life.But no one can actually taste a recipe. We can only taste the product of a chef’s efforts to follow one. It is much the same with sharia; it is believed to be the perfect Law of God, but it is impossible to know it directly. Instead, we know it through the interpretation of imperfect human beings – Muslim legal scholars – who, quite remarkably, admit their own fallibility. The rules they extrapolate from scripture are thus called fiqh, which literally means understanding, reflecting the principle that every fiqh rule is only a scholar’s best understanding of sharia, nothing more. This is a very creative – and I think the only – way to engage in religious lawmaking. As world history illustrates, claiming to speak for God without admitting the possibility that one could be wrong is very dangerous fire for humans to play with.
- Fiqh is fallible, and pluralisticFiqh lawmaking is based on accepting the impossibility of knowing God’s Law with certainty, but not the futility of trying. To create a fiqh rule, a Muslim legal scholar must perform ijtihad – an exhaustive process of jurisprudential analysis. Once past the ijtihad bar, fiqh rules acquire a unique quality: They are all equally valid. This is because there is no way to know for sure which ones are correct (and there is no Muslim “church” to designate favorites). As a result, all fiqhefforts are respected as equally legitimate understandings of sharia – even those that contradict each other.The sharia-ban campaign is fond of quoting some classical fiqh rules to argue that sharia is violent, oppressive and antithetical to American values.20 A simple appreciation of the difference between sharia and fiqh, however, reveals the error in this argument. Quoting one (or even more than one) fiqh rule does not define sharia any more than quoting Plessy v. Ferguson defines the American Constitution. It was not the Constitution that endorsed the oppression of black schoolchildren in the United States, it was one interpretation of the Constitution that did so.
- Fiqh pluralism means fiqh choiceBecause all fiqh understandings of God’s Law are equally valid, the landscape of fiqh is one of legal pluralism. Over time, collections of fiqh scholars formed into schools, each with its own signature interpretive methodology and collection of rules on topics such as property, contracts, family and criminal law.21 Individual Muslims wishing to live by sharia then choose which fiqh school to follow. Fiqh pluralism thus allows Islamic law to be tangible enough for everyday Muslim use, but still flexible enough to accommodate evolution and personal choice. For Muslims, there is one Law of God, but there are many schools of fiqh articulating that Law here on earth. That simple fact is what makes discussing sharia so challenging in the West where religious law is expected to be exact, uniform and uncontestable by believers.
- Extremists reject fiqh pluralismWhen anti-sharia activists myopically quote some fiqh rules and call them sharia, they fail to acknowledge the forest of fiqh alternatives that exists beyond those trees. Ironically, this is the same attitude taken by Muslim extremists, who reject fiqh pluralism because they believe their fiqh choices are correct, and refuse to entertain the possibility that they might be wrong (or at least that others have an equal chance at being right). In other words, radical Islam is not so much about extreme fiqh rules (those can always be rebutted in the marketplace of fiqhpluralism), but rather about narrowness of mind – the unflinching certainty that one’s preferred religious rules are how everyone should live. Some radical Muslims are even willing to force others to comply with their view, sometimes by taking over state power, sometimes through violence.This is why they fall outside the mainstream of Islamic thought. Their attitude denies the founding principle of Islamic jurisprudence – that humans cannot know God’s Law for sure. From a sharia-minded perspective, fiqhuniformity is radicalism. Fiqh scholars operated from the premise that oppression results when respect for religious legal pluralism is lost – when some become so sure of their understanding of God’s Law that they seek to limit the different understandings of others.22Ironically (but perhaps not surprisingly), anti-sharia activists sound very much like radical Muslim extremists. They repeat the singular (global jihadist) definition of sharia promoted by the world’s most radical Muslim extremists, and they also prioritize legal uniformity and eschew religious legal pluralism. By seeking to ban consideration of sharia (and apparently all religious law) in American courtrooms, anti-sharia activists seek to narrow the range of religious practices that can find legal protection in the United States. Their vision is a “one law for all” 23 monochromatic secularism, instead of our current system that accommodates a variety of religious practices as long as they do not offend public policy.
- Sharia does not require state legislation of fiqhOne of the “sharia takeover” arguments is that sharia requires government legislation of sharia. It should now be clear that the phrase “legislation of sharia” is ambiguous because it does not specify a school of fiqh rules. After all, no state can really know if it is enacting “sharia,” because sharia is tangibly known only through many fallible fiqhinterpretations. The most a state can do is enact its preferred fiqh interpretation – but when it does so, we should recognize that it is making a choice among many equally valid fiqh options. Thus, no specific fiqhrule can be said to be “dictated by sharia.”So, how do Muslim countries such as Saudi Arabia, Pakistan, Iran and Sudan get away with imposing “sharia legislation” upon their populations? The short answer is because modern Muslim governments have merged two legal realms that used to be separate.24 Pre-modern Muslim legal systems were organized around two different types of law: fiqh and siyasa. Fiqh, we already know, is religious law created by legal scholars, fallible, pluralistic and Muslims have the freedom to select which fiqh to follow. Siyasa (literally “administration”) is different in kind and application. Siyasa is state law created by Muslim rulers, based not on scriptural interpretation but on what is needed for public order (maslaha). It covers topics on which the scripture has little or nothing to say, such as traffic laws, zoning, marketplace regulations and public safety, and is usually applied uniformly to everyone, enforced with the police power of the state.The separate legal realms of fiqh and siyasa protected fiqh pluralism, and thus individual religious freedom. Rulers themselves facilitated fiqh pluralism by appointing judges from different fiqh schools, giving people access to state-enforced adjudication of their fiqh-based legal conflicts according to their school of choice. This practice included non-Muslims. In pre-modern Muslim societies, it would be normal, for example, for one couple to get divorced under Maliki fiqh, another under Hanafi fiqh, and another under Jewish halakha.But Muslim governments today are a deliberate departure from the pre-modern constitutional model that recognized a separation of fiqh and siyasa law. Instead, they are built on the nation-state model inherited from colonialism, where the government has a monopoly on all lawmaking power and there is no legally protected space for fiqh pluralism. When law is centralized in this way, these governments can easily be pressured to legislate and enforce one set of fiqh rules on everyone. This approach merges fiqh and siyasa power in a pseudo-theocratic way that was not possible in pre-modern systems. The result can be oppression of religious freedom, not only of non-Muslim minorities but also of any Muslim who follows different fiqh rules than those enforced by the government. Most importantly, all this has occurred because of contemporary politics, not because sharia demands it.
This is not really about sharia. This is about America.
There is one last glaringly obvious reason why there is no “sharia threat” to America: the Establishment Clause. Any attempted sharia legislation would simply be struck down as an establishment of religion. Given this reality, the campaign to ban sharia appears not as a movement to stop a sharia takeover, but instead to narrow the range of religious practice protected by American law. This fits with the campaign’s condemnations of multiculturalism. Anti-sharia activists argue that multiculturalism is dangerous because it opens the door to “creeping sharia.”25 The greater the fear of sharia, the stronger the argument against multiculturalism and diversity in the American public (and political) sphere.
Ultimately, then, the sharia-ban campaign is not really about sharia. It is about who we are as Americans. It is about what sort of secularism we want to espouse – European assimilationism, or American religious pluralism? Will we prioritize legal homogeneity or individual freedom? Census predictions estimate that by mid-century, there will no longer be a racial majority in the United States: We will truly be a country of multiple minorities.26 What forms of religious pluralism, cultural diversity and personal life choices will be enabled to thrive in the United States of the 21st century?
Here is a thought. What if sharia – the very ideology that has been so demonized in America – has some useful insights on these questions? The scholars of sharia sought stability not by forcing uniformity, but by finding ways to embrace multiplicity without sacrificing coherence. A quick look at both Muslim and American history illustrates societies that were at their worst when they insisted upon rigidity and sameness, and at their best when they were not scared by difference. Perhaps we could embrace the significance of that now. We might even learn something from Muslim experiences with sharia, if only we could stop reducing it to something that it is not.
- Speech to the American Enterprise Institute, July 29, 2010, http://www.youtube.com/watch?v=oMvQ95ftvYI.
- Wajahat Ali, Eli Clifton, Matthew Duss, Lee Fang, Scott Keyes and Faiz Shakir, “Fear, Inc.: The Roots of the Islamophobia Network in America,” Center for American Progress, August 2011, http://www.americanprogress.org/issues/2011/08/pdf/islamophobia.pdf.
- American Public Policy Alliance, http://publicpolicyalliance.org/?page_id=195.
- Senate Bill 1028, as introduced in March 2011, http://www.capitol.tn.gov/Bills/107/Bill/SB1028.pdf.
- This designation was to be made by the state attorney general based on determinations that include: (1) that the organization adhered to sharia, and (2) “engages in, or retains the capability and intent to engage in, an act of terrorism,” Senate bill 1028.
- See State Question No. 755, available at http://www.sos.ok.gov/documents/questions/755.pdf.
- The American Public Policy Alliance website includes several sharia-related links, but no links or references to any other foreign or religious law, http://publicpolicyalliance.org.
- The stated goal of the movement is to pass legislation banning sharia in every state and in the federal government. Newt Gingrich has specifically called for a federal sharia ban. See “Gingrich Calls For Federal Ban On Shariah Law in US,” TPMDC, September 18, 2010, http://tpmdc.talkingpointsmemo.com/2010/09/gingrich-calls-for-federal-law-banning-shariah-law-in-us.php.
- American Civil Liberties Union Program on Freedom of Religion and Belief report, “Nothing to Fear: Debunking the Mythical ‘Sharia Threat’ to Our Judicial System,” May 2011, http://www.aclu.org/religion-belief/nothing-fear-debunking-mythical-sharia-threat-our-judicial-system.
- Devin Dwyer, “GOP Presidential Hopefuls Blast Sharia Law in Pre-Primary Rhetoric,” ABC News, March 29, 2011, http://abcnews.go.com/Politics/tim-pawlenty-gop-presidential-hopefuls-blast-sharia-law/story?id=13238930 – .TvK5vmB8xl0.
- CBS News, “Herman Cain on Having a Muslim in his Cabinet,” published June 9, 2011, http://www.youtube.com/watch?v=Vf-RiiC7w-o.
- For some details, see Michael Helfand, “Religious Arbitration and the New Multiculturalism: Negotiating Conflicting Legal Orders,” New York University Law Review 86 (2011).
- This includes the recent New Jersey case, S.D. v. M.J.R., often cited by anti-sharia advocates to imply that American courts are tolerating Muslim religious arguments to excuse what would otherwise be considered sexual assault. In that case, the state court of appeals unequivocally rejected the apparent Muslim cultural defense and allowed the wife a restraining order against her husband. See S.D. v. M.J.R., 415 N.J. Super. 417 (N.J. Super. App. Div. 2010). Needless to say, no legislative ban on sharia was necessary to get to this result.
- For a more detailed discussion of cases involving Islamic family law in American courts, see Asifa Quraishi & Najeeba Syeed-Miller, “No Altars: A Survey of Islamic Family Law in the United States,” in Women’s Rights and Islamic Family Law: Perspectives on Reform, Lynn Welchman (London: Zed Books, 2004). Another useful resource with some more recent cases is the Sharia Index by Abed Awad and Noura Jebara, http://shariaindex.com.
- Aleem v. Aleem, 931 A. 2d 1123 (2008).
- Malik v. Malik, 638 A. 2d 1184 (1986).
- In Re Marriage of Obaidi, 226 P. 3d 787 (2010), Zawahiri v. Alwattar, 2008 Ohio 3473 (Ohio Ct. App. 2008).
- The original Tennessee anti-sharia bill began with language to this effect. See supra note 5.
- Andrea Elliott, “The Man Behind the Anti-Shariah Movement,” New York Times, July 30, 2011, http://www.nytimes.com/2011/07/31/us/31shariah.html?pagewanted=all.
- The Center for Security Policy states: “Shariah institutionalizes discrimination against women, deprives people of freedom of expression and association, criminalizes sexual freedom, and incites hatred and violence against people of certain social groups. As manifested in countries officially ruled by Islamic law, shariah condones or commands abhorrent behavior, including underage and forced marriage, ‘honor killing’ (usually of women and girls) to preserve family ‘honor,’ female genital mutilation, polygamy and domestic abuse, and even marital rape,” http://shariahthethreat.org/a-short-course-1-what-is-shariah.
- For more on these different fiqh schools and their respective methodologies compared with the methodologies of American constitutional interpretation, see Asifa Quraishi, “Interpreting the Qur’an and the Constitution: Similarities in the Use of Text, Tradition and Reason in Islamic and American Jurisprudence,” Cardozo Law Review 28 (2006): 67.
- The moment in Muslim history when Muslim jurists stood for this principle – against state power attempting to enforce belief – is called the mihna. For more on this historical event and its impact on Islamic law and government, see Marshall G.S. Hodgson, The Venture of Islam: Conscience and History in a World Civilization I: The Classical Age of Islam, (Chicago: The University of Chicago Press, 1974) 285-319, 479-89.
- This was the slogan of a similar anti-sharia campaign in Ontario, Canada, prompted by a planned addition of Muslim tribunals to the existing religious arbitration system. Ultimately, the anti-sharia advocates won the day. “There will be no Shariah law in Ontario,” said Ontario Premier Dalton McGuinty. “There will be no religious arbitration in Ontario. There will be one law for all Ontarians.” CTV News, September 12, 2005, http://www.ctv.ca/CTVNews/TopStories/20050912/mcguinty_shariah_050911.
- For more on the topic of centralized state power and how it differs from pre-modern Muslim societies, see Sherman Jackson, “Legal Pluralism Between Islam and the Nation-State: Romantic Medievalism or Pragmatic Modernity?,” Fordham International Law Journal 30 (2006): 158.
- See, for example, Salim Mansour, Delectable Lie: A liberal repudiation of multiculturalism, (Brantford: Mantua Books, 2011).
- Hope Yen, “U.S. Minority Population Could Be Majority By Mid-Century Census Shows,” Huffington Post, June 10, 2010, www.huffingtonpost.com/2010/06/10/us-minority-population-co_n_607369.html.