It’s All About Abortion! Douthat’s Misguided Attempts to Attack Planned Parenthood

Amie Newman

Ross Douthat is at it again - calling to defund Planned Parenthood, the health care provider that offers millions of Americans access to care critical for preventing unintended pregnancy and caring for ones' health.

Is there anything, at this point, that can explain Ross Douthat’s hubris in attacking a health care provider that offers care to millions of low-income Americans, as health care becomes more a privilege than a right for all Americans?

His latest column reveals he enjoys making baseless claims to support
his belief system. Douthat, like many anti-choice movement
members, wants to strip women (and men) of a certain income level of this country of reproductive
and sexual health care because he doesn’t like that some
providers offer comprehensive, legal medical procedures with which he doesn’t agree. Douthat is opposed to legal abortion, so he
painstakingly plays off of a Family Research Council fabricated controversy over Planned Parenthood – the provider nationwide that happens to
represent one of the few options remaining for women (and men!) of a
certain income level who need (no, not want) critical health care
like contraception, family planning, sexually transmitted infection
testing and treatment, HIV testing, annual exams, Pap smears, and

Even William Saletan acknowledged what Douthat’s "campaign" is really about –  abortion. Saletan goes so far as to call Planned Parenthood the most "effective pro-life organization in the history of the world."

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But the Family Research Council (FRC) isn’t buying it. They claim, via an email today, that Planned Parenthood is "awash" in funds and that if Planned Parenthood truly wanted to decrease the number of abortions, rather than providing birth control, contraception and family planning (you know, those things proven to actually prevent pregnancy and STIs), they should just "stop providing them."  Because, you know, if Planned Parenthood stopped providing abortions, unintended pregnancy would magically disappear.

Douthat’s post is truly
as painful to read (in its lack of common sense and evidence-based reasoning) as the FRC email. As we engage in a nationwide discussion on the
absolutely horrifying state of our health care system – one in which millions
of Americans are forced to go without care, including
reproductive and sexual health care, in part because health care providers can no longer afford to treat those who
require Medicaid subsidies or to provide care on a sliding scale
basis, Douthat and the FRC want to refocus Americans’ attention on
dismantling an organization that does provide such care. Planned Parenthood steps in, with the aid of tax dollars (and where
else would Douthat like to see “his” tax dollars go in order
to ensure health care for the millions of Americans who need STI
prevention services, HIV testing, contraception, family planning,
annual exams, Pap smears and more?) in order to provide these
services. Yes, they also provide abortions. And, yes, Douthat and
others do not like abortion. But, here’s the thing:

  • Planned Parenthood
    must (by federal law) keep their abortion services separate from
    their other services. The funding they receive to ensure that
    millions of Americans are given access to critical reproductive and
    sexual health care services must be funneled to those services.
    Federal law dictates that taxpayer money cannot pay for abortions.
    If Douthat has evidence that the organization is behaving in a
    fraudulent manner in this regard, then there’s a story here.
    If not, Douthat is simply registering his frustration with the fact
    that a legal medical procedure for women can be provided by an
    organization that also receives federal funds to provide other
    health care. I’m afraid Douthat has a big battle in front of
    him. What about those folks who believe contraception is murder?
    Should we bar health care providers who offer contraception to
    patients from receiving federal or state money too? What about
    independent physicians in private practice who perform abortions and
    also accept Medicaid subsidy for low income clients for other
    services (though, as I mentioned above, they are fewer and farther
    between these days)?

  • While
    Douthat tries to turn that 3% of Planned Parenthood costs spent on
    abortion care into a 250,000 number-of-abortions outrage he’s still
    left with the original (true) fact – 3% of Planned Parenthood’s
    services are abortion services. Which means that 97% of services
    Planned Parenthood provides are reproductive and sexual health care
    services which are not abortion. Douthat comes awfully close to admitting that the anti-choice
    movement is anti-contraception as well. He complains
    that 250,000 abortions/year are too many, but what is his
    answer? Defund Planned Parenthood, the organization that ensures
    that millions of young women and men are given the preventive tools,
    care and information to avoid unintended pregnancy.

a former women’s health center employee and part of the
reproductive health movement that prioritizes prevention, education
and trust, this next part of Douthat’s “argument”
makes my head spin. Douthat tries to “prove” that Planned
Parenthood is somehow fudging the numbers by using an article
Charlotte Allen wrote:

Just three percent,
hmm? Why, that makes it sound like Planned Parenthood almost never
performs abortions. Of course, the reality is rather different, as
Charlotte Allen noted last year:

The 3 percent
pie slice in the 2005-06 financial report, representing 264,943
abortion customers served, can only be described as deliberately

So, here we go again.
First of all, as any current or former nonprofit employee of a service
organization understands, in an annual report, you categorize
services in terms of percentages. If Planned Parenthood’s
abortion services make up 3% of their services, then categorizing this fact isn’t “sneaky” – it’s true.
But more than that, the way Douthat uses Allen’s reasoning to “prove” how Planned Parenthood tweaks
this number is stunning in its ability to demonstrate how little
anti-choicers understand about women’s health care provision
and how badly they want to politicize women’s health care at
any cost


One way Planned
Parenthood massages the numbers to make its abortion business look
trivial is to unbundle its services for purposes of counting. Those
10.1 million different medical procedures in the last fiscal year,
for instance, were administered to only 3 million clients. An
abortion is invariably preceded by a pregnancy test–a separate
service in Planned Parenthood’s reckoning–and is almost always
followed at the organization’s clinics by a "going home"
packet of contraceptives, which counts as another separate service.
Throw in a pelvic exam and a lab test for STDs–you get the picture.
In terms of absolute numbers of clients, one in three visited Planned
Parenthood for a pregnancy test, and of those, a little under one in
three had a Planned Parenthood abortion.


Okay, so, for the sake
of anti-choice advocates who want to see abortion criminalized, I’ll
address Allen’s points but I am hopeful that Rewire
will present an actual health care provider’s perspective to
crush this nonsense.

Planned Parenthood
isn’t “massaging” numbers by separating out
numbers of reproductive and sexual health care services
provided to women either before or after an abortion. When a woman
comes to a health care provider with an unintended pregnancy and
wishes to discuss her (legal!) options, she is first asked to take a
pregnancy test. This is, of course, a separate service from an
abortion procedure. The medical provider needs to know for sure that
this woman is pregnant first. Then they can discuss options:
continuing the pregnancy and parenting the child, continuing the
pregnancy and working with adoption services, or having an abortion,
thus terminating the pregnancy. That’s what health providers do
– should they instead, in Allen and Douthat’s world –
ask women to come in with a used pregnancy test? Secondly, Planned
Parenthood does not provide prenatal or childbirth services. Women
who visit Planned Parenthood for a pregnancy test are more than
likely already thinking about abortion as an option.

Secondly, Allen’s
condescending description of a "going home"
packet of contraceptives’ post-abortion reveals her true
feelings about contraception. While I can only suppose that the
medical offices of Allen and Douthat would send women away
post-abortion without the tools to actually prevent unintended
pregnancy again, most health care providers in this country (and all
mainstream medical associations) understand that ensuring women’s
access to contraception and family planning is critical to a healthy
life. It is unquestionable at this point that access to
contraception, globally, improves women’s health and lives,
elevates their status in society and is only beneficial
for the health of a nation. As Guttmacher puts it (PDF),


In addition to
improved health, sexual and reproductive health services contribute
to economic growth, societal and gender equity, and democratic


But Douthat uses Allen’s quote as a “gotcha” for Planned
Parenthood. Again, providing women with the means, post abortion, to
prevent unintended pregnancy does not catch Planned Parenthood in
some elaborate scheme – it catches them at doing exactly what
they should be doing, and what we should all be grateful they are
doing: providing women and families with the means to prevent
unintended pregnancy and STIs.

Ultimately Douthat’s
entire article will resonate only with the fiercest of anti-choice
advocates. As has been made clear this election season, and through
more polling than one can count, Americans support ensuring access to
health care for women – even (!) reproductive and sexual health care.
In addition, they oppose piling on even more legal restrictions
based on narrow, fundamentalist religious perspectives. Instead,
Americans are desperate to invest more time, energy and resources
into those programs – both advocacy and service –that
focus on prevention and education. It’s that darn common ground
concept that Douthat doesn’t like. Unfortunately for women,
though it’s most certainly the fuel for our fight, finding
“common ground” in the reproductive health movement is
about much more than “gotchas” and hot-button
ideological accusations. It’s about our health and lives.

News Family Planning

Lawsuit Challenges Arizona’s Attempt to Defund Planned Parenthood

Nicole Knight Shine

The Republican-backed law specifically targets abortion providers, excluding any facility from Medicaid that fails "to segregate taxpayer dollars from abortions, including the use of taxpayer dollars for any overhead expenses attributable to abortions.”

Planned Parenthood and the American Civil Liberties Union (ACLU) asked a federal court to block an Arizona law defunding Planned Parenthood, arguing in a legal challenge filed Thursday that the Arizona measure is “illegal.”

The GOP-backed law, signed by Republican Gov. Doug Ducey in May, specifically targets abortion providers, excluding any facility from Medicaid that fails “to segregate taxpayer dollars from abortions, including the use of taxpayer dollars for any overhead expenses attributable to abortions.”

Federal law already bars health-care providers from using Medicaid dollars for abortion care, except in cases of rape, incest, or life endangerment.

In an 18-page complaint, the plaintiffs argue that the restriction is impermissible under Medicaid statutes, and they ask for an injunction on the law, which goes into effect August 6. Planned Parenthood said in an emailed statement that the law could slash funding for birth control, cancer screenings, and preventive care, affecting more than 2,500 Medicaid patients in the state.

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The Arizona Health Care Cost Containment System, the state Medicaid agency, did not respond to a request for comment.

Jennifer Lee, staff attorney at the ACLU, called the Arizona law “another attempt to intimidate doctors who provide abortion and to punish low-income women in particular,” in a statement announcing the lawsuit. Planned Parenthood operates 11 medical centers in the state, including three in underserved and impoverished communities with high rates of infant mortality, according to the court filing.

At least ten states, including Arizona, have attempted to strip Planned Parenthood of funding—the fallout from a string of deceptive smear videos masterminded by David Daleiden, the head of the anti-choice front group the Center for Medical Progress, who now faces a felony record-tampering charge.

“This case is about the people who rely on us for basic care every day,” said Cecile Richards, president of Planned Parenthood Federation of America, in an announcement of the Arizona suit. “We’ll continue fighting in Arizona, and anywhere else there are efforts to block our patients from the care they need.”

The Arizona law represents the state’s second attempt to defund Planned Parenthood. In 2014, the Ninth Circuit Court of Appeals affirmed a lower court decision finding a similar defunding measure, HB 2800, violated federal Medicaid law.

In April, the federal Centers for Medicare & Medicaid Services sent a letter to all 50 states saying that cutting funding to qualified providers solely because they provide abortion care violates federal law.

Independent analysis suggests gutting Planned Parenthood funding exacts a toll on health care.

2015 report from the Congressional Budget Office indicated that health-care access would suffer under Planned Parenthood funding cuts, with the potential for $650 million in additional Medicaid spending over a decade and thousands of more births.

In Texas, births surged 27 percent among low-income women who were using injectable birth control but lost access to the service when the state cut Medicaid funding to Planned Parenthood, according to a study published in the New England Journal of Medicine.

Investigations Media

Exclusive: Law Enforcement Calls Daleiden ‘Uncooperative’; Documents Reveal More CMP Lies

Sharona Coutts

“David Daleiden contacted our agency May 21st of 2015 and filed a criminal report against StemExpress here in Placerville,” a spokesperson at the El Dorado County Sheriff’s Office told Rewire. “All he was, was a reporting party. He didn’t consult with us and he didn’t cooperate with us. In fact, I’d characterize him as uncooperative.”

See more of our coverage on the anti-choice front group the Center for Medical Progress here.

In late May of last year, David Daleiden was reaching the culmination of a project he had been working on for three years. Over that time, the anti-choice activist had been living a lie of his own creation. He had set up a bogus company, complete with a fake website, and corporate officers whose names were in fact aliases.

He had enlisted half a dozen other anti-choice activists to help him, most notably Sandra Susan Merritt, a 63-year-old resident of San Jose, California, who—using the alias Susan Tennenbaum—posed as the CEO of the bogus company, Biomax Procurement Services.

Together, Daleiden—going by Robert Daoud Sarkis—and Merritt hopscotched the country, traveling from California to Colorado, Florida, Maryland, Texas, and Washington, D.C. They attended conferences for abortion providers and parlayed those attendances—and the trust and credibility they engendered—into visits to abortion clinics, where the pair secretly recorded meetings and site visits and tried to goad their targets into making statements that could be twisted to look like evidence of illegal activities.

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By May 21, Daleiden was nearly ready to bring his elaborate scheme to a head. The next night, he and “Tennenbaum” were scheduled to have dinner with executives from StemExpress, a tissue procurement company based in Northern California. As he had done for virtually every encounter as a Biomax official, Daleiden planned to secretly video record the meeting and then to release doctored versions of that footage to the public.

But this time, Daleiden did something different. On the eve of this particular meeting, he delivered a bundle of so-called evidence of alleged wrongdoing by StemExpress to the El Dorado County Sheriff’s Office, claiming that the company had engaged in a range of crimes including trafficking in human organs and human tissues, and “homicide of babies born alive during the abortion procedure,” according to legal documents obtained by Rewire.

In a deposition taken late last year, Daleiden would claim—in sworn testimony, under penalty of perjury—that the purpose of his meeting with the El Dorado County Sheriff’s Office was “to coordinate [his] investigations going forward on how to bring StemExpress criminal conduct to light.”

Following his lawyer’s advice during that deposition, Daleiden refused to say more about that meeting, or the other authorities he had supposedly “coordinated” with in his spying campaign, but he did heavily imply that the El Dorado County Sheriff’s Office was just one of the “governmental authorities” that he met with “contemporaneously with the actual undercover operation.”

The notion that law enforcement authorities were actively colluding with Daleiden and his associates in conduct that has resulted in criminal indictments is curious, to say the least.

It’s just one of the loose ends that surrounds Daleiden’s project, a year after he released the first smear video against Planned Parenthood (the organization and some of its individual employees), abortion providers in general, and companies that assist in the procurement of tissue for medical and scientific research. 

Despite the dozen-odd state and federal investigations his project sparked, the multiple civil and criminal cases it sent ricocheting through state and federal courts, and the untold damage it caused to companies, organizations, and individuals targeted by his group, many questions remain about who funded Daleiden, which politicians supported him, and who else was involved in his operation—including the identities of the other operatives that posed as Biomax employees. 

Using freshly obtained legal documents, Rewire has taken a look back at some of the most mysterious aspects of the Daleiden affair, comparing what we have learned since the videos were first released with what remains unknown or unclear.

What emerge are some disturbing claims that have yet to be fully resolved, not least of which is the extent to which members of Congress were aware of—or involved in—planning or executing Daleiden’s campaign.

El Dorado Sheriff’s Office: Daleiden Was “Uncooperative”

When Daleiden met with the El Dorado County Sheriff’s Office, he handed over a report he had prepared containing his “best kind of summary or list of the different California and federal laws that are implicated in the actions between StemExpress and Planned Parenthood,” along with “a few representative examples of the evidence that CMP gathered that indicates probable cause for violations of those laws,” according to a transcript of the deposition he gave on December 30, 2015.

When Rewire contacted the El Dorado County Sheriff’s Office about this anecdote, its spokesperson, Jim Byers, said he clearly remembered Daleiden’s visit, but disputed Daleiden’s characterization that his office was “coordinating” with the spying project.

“David Daleiden contacted our agency May 21st of 2015 and filed a criminal report against StemExpress here in Placerville,” Byers said. “All he was, was a reporting party. He didn’t consult with us and he didn’t cooperate with us. In fact, I’d characterize him as uncooperative.”

Byers said that it was unclear to his colleagues what exactly Daleiden wanted them to do with the information he had provided. Flipping through the report while speaking with Rewire, Byers explained: “It just says that he had been conducting a multiyear investigation and was going to go public with it and wanted to make this report to us, but when we asked him to hold off so we could investigate his claims, he went ahead and went public anyway.”

The reason the sheriff’s office asked Daleiden not to go public was because doing so would hamper any investigation they might do into the allegations Daleiden had made. “That’s very common, for us to ask something like that, because then the people we need to talk to aren’t going to talk to us,” Byers said. “He declined to follow our request.”

Regardless, the sheriff’s office spent months investigating Daleiden’s claims; they found no evidence of illegal conduct by StemExpress. As is routine, the sheriff’s office then referred the matter to the El Dorado District Attorney for further review. Dave Stevenson, the spokesperson for the district attorney’s office, told Rewire he was unable to comment on the matter as the investigation is ongoing.

If it seems odd that Daleiden would make a report to law enforcementbut not give them any time to actually investigate the allegations he’d made and actually jeopardize those investigations—that might be because the act of making the report itself was part of Daleiden’s legal strategy.

Daleiden was consulting with the Life Legal Defense Foundation for at least two years prior to releasing his videos, according to published reports. It’s therefore likely that he knew that California creates criminal and civil penalties for people who intentionally make a secret recording of a person in a private meeting without their consent. And indeed, that’s one of the key charges within the lawsuits that have been filed against Daleiden and his co-defendants.

It’s also likely that Daleiden and his advisers knew that there is an exception to that law for people who make a secret recording “for the purpose of obtaining evidence reasonably believed to relate to the commission by another party to the communication of the crime of extortion, kidnapping, bribery, any felony involving violence against the person.”

Throughout the deposition he made on December 30, Daleiden maintained that he believed he was exposing criminal conduct as a justification for his spying activities. Merritt made similar claims in the deposition she gave in the same case, on December 29. In particular, both insist they believed they were recording evidence of murder.

It appears plausible that Daleiden made his report not because he thought the county sheriff’s office would really investigate, but because he anticipated that once he published the illegally taped videos, he would be charged with a crime, and he was simply laying the groundwork to be able to show a court later on that he had filed the criminal report as evidence of his belief that he had uncovered a crime.

Daleiden did not reply to Rewire‘s questions about whether this was in fact his legal strategy. Catherine Short, his lawyer at Life Legal Defense Foundation, did not immediately respond to our emails seeking comment. 

However, for that defense to work, a person must show they had an honest and reasonable belief that they were uncovering a crime. And when it came to the specifics of the supposed crimes they were uncovering, both depositions are striking for the extent to which Daleiden and Merritt refused or were unable to give clear definitions of those offenses.

For instance, both Daleiden and Merritt were reluctant to answer questions about who, if anyone, they believed had actually committed the murder they were supposedly reporting, despite that being one of their key allegations. Both Daleiden and Merritt made vague statements about “doctors” being responsible, or about the “abortion industry” writ large, but when it came to the specifics of how anyone at StemExpress could have been guilty of murder, their answers were evasive. 

In one chilling passage, Daleiden gave stammering and elusive answers to questioning over whether he believed that one of the people who assisted him in his smear campaign—a former StemExpress employee named Holly O’Donnell—had provided him with evidence that she had herself committed murder. Discussing O’Donnell’s account of one incident she related where she claimed to have procured fetal brain tissue, Daleiden initially said he did not believe O’Donnell had murdered that fetus. But under questioning about the overall processes involved in preparing tissue samples, Daleiden’s answers became confused.

After Daleiden noted that O’Donnell went with him to his first meeting with El Dorado law enforcement, the StemExpress lawyer asked: “Did you ever tell Holly that you thought she should be investigated by El Dorado County for her conduct?”

Daleiden never definitely said “no,” but rather, “I think that, you know, the testimony of people who worked at StemExpress is—you know, is relevant to that investigation but I think the ultimate culpability is with the—with the business entity.” He also said he would “put culpability on the doc,” but then he said:

I’m not sure what Holly’s obligations were there. But, you know, but this is—this is highly speculative and, like I said, this is why I think this is really serious information that I—and really serious allegations and actions that—that needed to be brought to law enforcement, which is what I did.

Ultimately, Daleiden’s lawyer summarized his client’s position on O’Donnell’s potential guilt thus: “He explained as best he could that it would be the doctor or it would be [a different StemExpress employee] and it’s ambiguous as to Holly’s role at that point.”

Merritt appears to go further. Towards the end of her deposition, she was asked to clarify whether she believed that any StemExpress employees had committed murder. She described what she believed O’Donnell had done, and then said, “Yes, I believe that to be murder.”

One can only wonder whether O’Donnell was aware that Daleiden considered the possibility—or perhaps, had not considered the possibility—that he was giving law enforcement authorities evidence that she had committed murder, when she accompanied Daleiden to their offices and helped him with his “investigation.”

Rewire’s attempts to contact O’Donnell for her comment on that question were unsuccessful.

Further Evidence That Daleiden and His Associates Are Not Reporters

The very fact that Daleiden claimed—albeit incorrectly—to have been “coordinating” with law enforcement further undermines his dubious assertion that he is an investigative reporter. Reporters would seldom coordinate their efforts with law enforcement, except for rare instances where, by way of example, they might inform law enforcement if they had learned of an imminent risk to a person’s life or to national security.

The deposition also revealed Daleiden’s investigative methods to be far from objective, and in some respects, amateurish.

Under questioning from StemExpress’ attorney, Daleiden explained that much of his knowledge of how tissue or organ transplantation worked was based on “research,” which comprised Googling for journal articles, which he admitted to cherry-picking. He also based most of his understanding of the equipment used in heart transplants on watching videos that the equipment manufacturer had posted on its website and YouTube channel.

He relied disproportionately on the expertise of a scientist whose otherwise impressive credentials are marred by her support for widely debunked theories that vaccines are linked to autism. He used this patchwork knowledge to cobble together flawed theories about how fetal tissue is acquired, and the circumstances in which it could be used for research.

He even made assumptions about what medical professionals meant by the words “case” or “specimen”—he said he believed the people he filmed were referring to a fetus, when in fact those words can also refer to a particular organ or piece of tissue. He said that he didn’t give the subjects of his secret video recordings the opportunity to clarify what they meant by these terms because he didn’t want to blow his cover—or as he put it, he didn’t want to get greedy for information and “get lost in the Cave of Wonders like Aladdin and go like looking for all the other treasures.” He just ran with his own assumptions, something no professional reporter would do. 

And he acknowledged that the reason he embarked on his project was because he had formed an unshakable belief that abortion providers engaged in unlawful trafficking of human organs and tissues, instead of remaining open-minded about the facts and attempting to report against his own biases, as a real reporter would do. None of the multiple investigations into Planned Parenthood have found any evidence that substantiate Daleiden’s allegations. Indeed, Daleiden manipulated his videos to omit passages where the targets of his campaign explicitly told him that profiting from human tissues was unethical and illegal.

Merritt’s deposition is even more astonishing in terms of just how flimsy her claims to be a reporter turn out to be.

Like Daleiden, Merritt is trying to assert that she is a reporter and therefore protected by the First Amendment.

A lawyer for StemExpress asked Merritt, “Do you consider yourself a journalist?”

Merritt answered, “Yes.”

The lawyer then asked, “Have you ever published any articles?”

Merritt answered, “I have not.”

She said she didn’t do any original research. She didn’t do any writing. She didn’t edit. Merritt specifically told the lawyer for StemExpress that her sole role in the ruse orchestrated by Daleiden was to wear a video recorder while playing the part of Susan Tennenbaum, which may explain why Daleiden has frequently referred to his associates as “actors.”

Wearing a camera does not a reporter make.

Which Members of Congress Knew About the Planned Smear Campaign, What Did They Know, and When? 

An especially curious aspect of this saga is how some members of Congress had seen at least one of the smear videos before Daleiden released them to the public. Rep. Trent Franks (R-AZ) and Rep. Tim Murphy (R-PA) both told Roll Call that they had seen the first video about a month before it was published. How and why they came to see the video, and what their role was in helping plan the political response to the tapes, if any, remains unclear.

But the following exchange during Daleiden’s deposition provided a tantalizing tidbit about that mystery.

In his December 30 deposition, Daleiden declined to answer the following questions from StemExpress’ lawyer:

When is the first time you spoke with anybody from, or had any contact with anybody from Congress?


When is the first time you provided any materials to anybody that is a member of Congress?

Daleiden responded: “I don’t think the answer to that question is a matter of public record so I’m going to follow the advice of my counsel.” He declined to respond.

Ostensibly, the reason Daleiden declined is that he believed it was outside the scope of that particular deposition, which was confined to some narrow legal arguments. However, there is an implication in the December 30 deposition that those questions were within the scope of a related case, along with questions about who funded Daleiden’s efforts, and information about the specific role of his board member, the anti-choice extremist and head of Operation Rescue, Troy Newman.

A year has passed since the videos were first released, and a lot of time and taxpayer dollars have been spent as a result of Daleiden’s endeavors. But a year is a short time in the life of a lawsuit, and many cases are still wending their way through state and federal courts. As they do, it is possible that we will learn more about these unresolved questions.

Time will tell whether the pattern Daleiden has established will continue: Instead of exposing wrongdoing by others, the only wrongdoing he has thus far managed to record and expose was his own.