Toothless International Human Rights: Genocide in Gaza

It strains credulity to believe that vengeance against the Palestinian residents of Gaza was not among the motives of the Israeli government’s ministers in retaliating for the Hamas attack against occupation on October 7, 2023. Within days, Israel’s president publicly accused every Palestinian in Gaza of being guilty. Because it cannot be assumed that every resident of Gaza who had voted Hamas into office was in favor of the attack, and the residents who had voted for the PLO could even less be assumed to be supportive of Hamas, the Israeli notion of collective justice is ethically flawed. Deficient as a subterfuge for the very human instinctual urge to inflict disproportionate vengeance, the espoused justification did not hold South Africa off from charging Israel with genocide at the International Court of Justice (ICJ). At the time, both South Africa and Israel were parties to the Genocide Convention. Because the ICJ was at the time the principal judicial body of the United Nations, the UN’s lack of enforcement power—notorious even on resolutions passed by the Security Council—meant that even a conviction could send the message that a national government can get away with even genocide.

In its accusation, South Africa claimed that Israel was “in violation of its obligations under the Genocide Convention” in that “acts and omissions by Israel . . . are genocidal in character, as they are committed with the requisite specific intent . . . to destroy Palestinians in Gaza.”[1] At the time (at the end of 2023), over 21.5 thousand people had been killed by Israel in Gaza since October 7, 2023, far outstripping the 1,200 Israelis who had been killed by Hamas and the 240 hostages during that period.[2] The disproportionality alone eviscerates claims of retaliation and thus “justice.” That a significant number of the Palestinians killed were innocents, including children, and 85 percent of the 2.3 million Palestinians there had been left homeless[3] and at least as many without sufficient food and medical care supports South Africa’s claim that “there are ongoing reports of international crimes, such as crimes against humanity and war crimes, being committed as well as reports that acts meeting the threshold of genocide or related crimes as defined in the 1948 Convention on the Prevention and Punishment of Genocide, have been and may still be committed in the context of the ongoing massacres in Gaza.”[4] Also in the final days of 2023, Israel’s finance minister, Bezalel Smotrich publicly accused the “2 million people” in Gaza of aspiring “to destroy the State of Israel” so only a few hundred thousand should be allowed to remain there.[5] Hence, South Africa’s government stated that it was “gravely concerned with the plight of civilians caught in the present Israeli attacks on the Gaza Strip due to the indiscriminate use of force and forcible removal of inhabitants.”[6]

One way to massively decrease population, the use of “indiscriminate bombing” was, according to U.S. President Biden, being used by Israel. Even though the unguided bombs could get at Hamas’ underground tunnels, the use of such bombs, especially in a densely populated urban context, was prohibited by international humanitarian law. American intelligence assessment suggested “that nearly half of the air-to-ground munitions that Israel has used . . . have been unguided.”[7] The Israeli government put out the following statement: “Israel is committed to international law and acts in accordance with it, and directs its military efforts only against the Hamas terrorist organization and the other terrorist organizations cooperating  with Hamas.”[8] Astonishingly, the statement added that Israel had been making “every effort to limit harm to the non-involved and to allow humanitarian aid to enter the Gaza Strip.”[9] This flies in the face of the nearly 2 million residents who had been displaced from their homes and with the extent of starvation. Just weeks before South Africa’s application, thousands of Gaza residents desperate for food had mobbed food-aid trucks in the city of Rafah.[10] Even Israel’s finance minister admitted that Gaza was a ghetto (so decreasing its population was justifiable).[11] Masha Gessen, who won the Hannah Arendt prize for speaking truth to power as Arendt did during the Eichmann trial, wrote that Gaza is “like a Jewish ghetto in an Eastern European country occupied by Nazi Germany.”[12] That Gessen was herself Jewish and had lost ancestors in the Holocaust did not stop her from “catching hell” for her statement. The presidents of Harvard, Penn, and MIT also caught hell for asserting that the context (of the war) could make political speech redressing Israel’s genocide with a corresponding one against Israel protected as free (rather than hate) speech, while Yale caved. Even a Yale alum can tip his hat to Harvard in the hope that Yale might take a lesson rather than fortify its truth, and instead humbly improve.

For its part, the Israeli government was in denial. As South Africa’s charges were made public, the state founded for victims of German atrocities had become a victimizer in striking back with vengeful disproportionality, and yet this was too much for the vengeful to see in their mirrors. The Israeli government’s Ministry of Foreign Affairs played the antisemitic card in claiming that South Africa was “calling for the destruction of the State of Israel,” which was blatantly untrue.[13] For his part, Prime Minister Netanyahu was saying that the attacks would continue for months.[14] Clearly, the Israeli government would dismiss any adverse ruling by the UN’s court on crimes against humanity leveled this time against Israel. For nothing short of a brick wall can arrest such stubbornness, especially when it is fueled by disproportionate vengeance. Yet the UN has shown itself to be utterly feckless, shirking even from standing up to its own members.

The root of the problem that enables a government to commit even a genocide with impunity, or invade another country unprovoked (e.g., Russia) and intentionally bomb civilians, is the absolutist interpretation of national sovereignty, which had come out of the writings of Jean Bodin (c. 1529-1596) in Six Books of the Commonwealth. Given the Reformation-fueled strife of his day, he “was convinced that peace could be restored only if the sovereign prince was given absolute and indivisible power of the state.”[15] The state’s sovereignty was absolute. A century later, Thomas Hobbes carried this political theory further in Leviathan. To be fully sovereign must include having the last say on theological doctrine and Biblical interpretation. Hence, the monarch in Britain is head of the Church of England. In the turbulent sixteenth and seventeenth centuries in Europe, absolute sovereignty was deemed worth the risk of the power being abused in tyrannical rule without any internal check. As for any normative check by other monarchs, none of them would have wanted to see their own absolute sovereignty impinged by an invading prince from another realm.

The norm that a government’s rule is a matter of a country’s internal affairs had survived even into the twenty-first century. The governments of Russia and China had been the most explicit in insisting that this norm be universally accepted. With the advent of human-induced climatic change and modern weapons of mass destruction, however, we might expect the norm to be challenged, but the ongoing impotence of the UN and the want of any serious proposals of reform that would involve national governments giving up some of their sovereignty suggests that the norm still had considerable staying power and would thus require a lot of energy to be dislodged from its privileged status as the status quo default. In other words, even as the harms from unchecked national power have increased tremendously, Bodin’s theory of absolute sovereignty has remained hegemonic.

So the Israeli government could simply enunciate false claims and not really have to worry about anything more than bad public relations from the charges at the International Court of Justice. Even genocide in retaliation for a much lesser, albeit horrific, attack could be protected by the sovereignty of the Israeli government.

The silent culprit may be the diffusion of responsibility globally as the rest of us watch the ongoing dire situation in Gaza (and Ukraine) as if we were paralyzed from demanding that our respective governments cede some authority militarily to the UN or a new international body empowered to enforce its decisions. The governments refusing to go along could be excluded commercially as well as diplomatically from those who have been willing to be held accountable themselves and thus cede some sovereignty in exchange for a voice (and vote) at the global table.

After more than a century of tremendous technological development—my grandfathers, for instance, witnessed the coming of cars, airplanes, radio, television, huge medical advances, and even computers—the retarded condition of political development really stands out—or should stand out—given the increased global interdependence and threats, including the scale of harm that a government can commit by means of military technology. That Nazi Germany could follow the Enlightenment should give us all pause in the trust we place in our governments, including their police and military forces. If we are Kantian rational beings, so too are we capable of tremendous rage that can snuff out what Adam Smith pointed to as the human imagination enabling sympathy for others in a “fellow-feeling.” Both Putin of Russia and Netanyahu of Israel have recourse to tremendous military force and yet arguably little if any sympathy even in the midst of such large-scale, disproportionate suffering. That the two men can get away with continuing to inflict even more suffering as long as they feel like it is reason enough for the defeat of Bodin’s political idea.

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1. Pierre Meilhan, Bethlehem Feleke, and Tamar Michaelis, “South Africa Files Genocide Case Against Israel at International Court of Justice Over Gaza War,” CNN.com, December 29, 2023.
2. Ibid.
3. Waffa Shurafa, Bassem Mroue, and Tia Goldenberg, “Israeli Strikes in Central Gaza Kill at Least 35 as Netanyahu Says War Will Continue for Months,” The Huffington Post, December 30, 2023.
4. Pierre Meilhan, Bethlehem Feleke, and Tamar Michaelis, “South Africa Files Genocide Case Against Israel at International Court of Justice Over Gaza War,” CNN.com, December 29, 2023.
5. Sanjana Karanth, “Senior Far-Right Israeli Official Admits Gaza Is A ‘Ghetto’ for Palestinians,” The Huffington Post, December 31, 2023.
6. Pierre Meilhan, Bethlehem Feleke, and Tamar Michaelis, “South Africa Files Genocide Case Against Israel at International Court of Justice Over Gaza War,” CNN.com, December 29, 2023.
7. Ibid.
8. Ibid.
9. Ibid.
10. “Chaotic Scenes as People Run after Lorries Carrying Aid in Gaza,” BBC, December 27, 2023.
11. Sanjana Karanth, “Senior Far-Right Israeli Official Admits Gaza Is A ‘Ghetto’ for Palestinians,” The Huffington Post, December 31, 2023.
12. David Mouriquand, “Author Masha Gessen Receives German Prize Despite Comments Comparing Gaza to Nazi-era Ghettos,” Euronews, December 18, 2023.
13. Pierre Meilhan, Bethlehem Feleke, and Tamar Michaelis, “South Africa Files Genocide Case Against Israel at International Court of Justice Over Gaza War,” CNN.com, December 29, 2023.
14. Waffa Shurafa, Bassem Mroue, and Tia Goldenberg, “Israeli Strikes in Central Gaza Kill at Least 35 as Netanyahu Says War Will Continue for Months,” The Huffington Post, December 30, 2023.
15. “Jean Bodin,” Internet Encyclopedia of Philosophy.

Israel vs. Gaza: Why Does the World Tolerate Unfair Fights within Countries?

In the very nature of occupation and in particular its attribute of a near-monopoly on military force within a given territory, the superior power is essentially inert to any normative constraints, whether from within or abroad. Such power can be drunk with anger, blatantly ignoring what even allies recognize as blatantly unfair actions. That such power may actually perceive the unfairness as fair to the innocent victims demonstrates just how much cognitive dissonance a human brain consumed with its will to power can muster, let alone tolerate, as a mental shield hiding the naked aggression. To be sure, it takes two to get tangled in a fight, so rarely is either party "the bad guy." Yet major dimensions of a conflict can be sliced and put under the proverbial microscope for close examination. Tolerance for an unfair fight, whether involving a rapist, a school-yard bully, or an occupying state, is problematic in not only the predominant aggressor but also any bystanders. In the case of Israel and Gaza in July 2014, the lopsidedness of the death-tolls stands out, as does the tacit refusal of the international community to step in and stop the fight as a result. 

After six days of missile-fire, the death-toll in Gaza had reached 156, with over 1,060 wounded. The U.N. estimated that 77% of the dead had been civilians.  Israel’s 1,200 airstrikes targeted some inherently civilian areas, including a center for the disabled, a mosque, and the home of the Gaza police chief. [1] Despite Israeli claims of having issued warnings, families were killed in their homes because they had not had time enough to leave before being hit. 

Meanwhile, Israel incurred no fatalities and only five people were injured.[2] Many of Hamas’ 700 missiles were intercepted by the U.S.-funded anti-missile “Iron dome.” In the past, such enabling prompted deadly hatred of Israel’s major financial and military supplier. Hence, refusing to do more than condemn the violence represented a long-term risk to the U.S. As if slapping the hand that was feeding it, the Israeli prime minister ignored the American president's pleas—doubtlessly confident of the power of the Jewish lobby in Washington, and thus of continued American aid of over $3 billion a year.[3]  Furthermore, prime minister Netanyahu defied the U.N. Security Council’s unanimous call for a cease-fire by unabashedly insisting there was no end in sight to the offensive.[4] Yet the international organization did not sanction Israel or cancel its membership. Internationally, parchment is particularly impotent when it comes to constraining an energized will to power; ethical suasion is like tissue-paper tossed in front of an accelerating train.  

All that hardware, in spite of any fatalities to justify the escalation. (Image Source: AFP)

In fact, the Israeli military was actually widening its bombing targets and extending the offensive to include troops on the ground. Four days into the foray of tanks and troops into Gaza, UNICEF reported that "the overwhelming majority of people killed so far are Palestinians."[5] Specifically, more than 500 had been killed, 121 of whom were Palestinian children, while 29 Israelis, all but one having been killed in the line of duty, had died.[6] As the incursion continued, the ratio widened, especially in regard to civilians killed. 

As of July 31, 2014

On August 3rd, Israel dropped a bomb on a U.N. school that was sheltering displaced civilians, killing 10 of them.[7] The Israeli government pointed to a Palestinian rocket launch nearby the school. Refusing to accord this claim legitimating status, Robert Turner, the operations director for the U.N. Palestinian refugee agency in Gaza, noted that the "locations of all these institutions [had] been passed to the Israeli military multiple times. They know where these shelters are. . . . How this continues to happen, I have no idea."[8] He concluded that the attack violates international law. "It is a moral outrage and a criminal act," he declared.[9] This moral problem can be distinguished from not only the legal argument, but also the unfairness of the quantitative imbalance in the number of deaths. Counting the attack on the shelter, 1,800 Palestinians and 60 Israelis had been killed in the conflict so far.

Escalation is also discernable in terms of the Israeli goals. Initially, the intent was to continue firing rockets until the rockets from Hamas stopped. Then, the ground offensive would go on until all the tunnels had been destroyed, though the actual extended goal may have been to fight until Hamas becomes paralyzed not only militarily, but politically too, within Gaza. At the very least, killing as many Hamas fighters and supporters as possible would mean that the party would not likely win another election in Gaza. It could indeed be said that in escalating its objectives, therefore, the Israeli government was being opportunistic. 

To be sure, Hamas had hardly been blameless; my intent here is not to defend that organization or even the Palestinian cause; rather, I am isolating a stark element of unfairness in the immediate fight in order to ask why human beings generally appear to be so willing to put power or political dynamics ahead of normative constraints. To maintain my focus on this particular imbalance in juxtaposition to the ethical principle of a fair fight, I am excluding property damage and even injury counts on both sides. In focusing on the death tolls exclusively, I am treating actual (rather than anticipated) deaths as constituting the bottom-line and asking why the people in the Israeli government and in governments around the world did not say in actions, "Ok, enough is enough; the actual (i.e., immediate) fighting has to end now, and we're going to step in and stop it." 

If the exchange of rocket-fire and Israel's ground offensive were part of a boxing match, the referee would have stopped the fight lest the stronger fighter, drunk with overwhelming power, kill the other man three or four times over. In such a case, a politically impotent referee would represent quite a danger, as would the aggressor of course. Faire le dessus est prévaloir; l’autre prérit.

Why did the world look on, "demanding" an immediate cease fire but yet refusing to put actions behind those words to make them stick? Even the Arab neighbors were uncharacteristically quiet, no doubt in part because some had internal rebellions of their own to keep contained. Moreover, power and money in support of Israel around the world, as well as the ironic generalized sense of deserved accommodation due to the Nazi holocaust in the twentieth century, have explanatory value. However, I submit that the inordinate weight that government officials around the world and the officials and members of international bodies such as the U.N. put on the doctrine of national sovereignty is also a key ingredient. 

Regarding the supervening power in the conflict, an opportunistic, escalating platform is two degrees of freedom from what the huge imbalance of killing ought ethically to have triggered in even the aggressor human beings. Perhaps our species fights to the death when given the chance; through the 1.8 million years in which our ancestors lived in small, vulnerable bands rather than large, complex social arrangements such as societies, nations, and a global community, forces of natural selection likely favored overkill given the threats from strangers and wild animals. Such an evolved instinctual defense-mechanism is not well suited for the socio-political artifices our organized predecessors built up in the blink of an eye. I contend that our structures magnify both the intensity and extent of the now-bad instinct to take out our adversaries before they can subjugate or kill us. Even in the fifth century, Augustine pointed to war as evidence that our species could be “far more cruel and bloodthirsty than wild animals.”[10] Both the underlying instinct and the organized extensions of warfare are relevant here. In other words, to account both for the lack of intervention internationally and the Israeli government officials’ escalation of the unfair fight, I find the source in the human instinct to wield power over other people, whether individually or grouped by some criterion often related to the power-interest, and from this basis I broaden out to how the urge is extended through human artifice.

In 1963 at Yale, Stanley Milgram conducted an experiment in which local residents selected at random operated what they thought were escalating electric shocks to other subjects in a "memory test." Actors played both those other subjects and the experts in lab coats whose task it was to have the true subjects increase the shock level at each successive wrong answer. In spite of the (recordings of) screams, 65% of the electric shock administrators (i.e., the real subjects) pulled the lever marked "XXX deadly electric shock." The subjects could not see the recipients, but could hear the (recorded) screams. Even this distance from the harm was sufficient for the majority of the subjects to administer what they thought was a fatal shock to punish a wrong answer to a memory test (which of course was rigged).

Although the lesson taken from the experiment concerned the extent to which human beings will do immoral acts in following orders, the fact that implementers throughout organizations use devices like gate-keeping to amass power, the subjects of the experiment can also be suspected as going ahead in part out of the pleasure that comes in exercising power over another human being. Psychological and physical distance from the target only tilts the balance further in the direction of succumbing to the pressure of a superior and putting the anticipated pleasure before any ethical reservations. I contend that this dynamic applies in the case of the Israeli government officials and military officers (and troops), owing in large part to the huge surplus of power at their fingertips over the Palestinians in Gaza. This is not to say that the same dynamic applies also to the Palestinians behind the rockets going into Israel, albeit with much less potent power and thus intensity. 

Making matters worse both with respect to the intensity of the dynamic and the scope of its destructiveness, the doctrine of absolutist national sovereignty has acted as an enabler. The artifice that came of age as complex social arrangements (i.e., the nation-state) expanded in the sixteenth and seventeenth centuries in Europe is far indeed from the state of nature, even as the doctrine gives the unsavory instinct more free rein. In addition to the larger territory and increased population subject to a government's military might, the power of the already powerful is magnified by its virtual monopoly made possible by the high external walls constructed out of the doctrine. 

As Hobbes advocates in Leviathan, the sovereign is to have all power in a kingdom or republic, to stave off civil war (Hobbes' own century being particularly bloody in this regard) and external interference from sovereigns of other countries. The people are thus at the mercy of the sovereign, who not only makes and enforces civic law, but interprets it and divine law too. 

Yet as the Hebrew Bible points out, the Abrahamic deity tends to have the last word, particularly with an unrighteous, unjust Israel. Of course, Yahweh also ostensibly had the ancient Hebrews commit genocide at Jerico because its occupants would not convert from worshipping Baal. Whether from an ethical or religious standpoint, it is difficult to see what normative force could possibly counter the natural proclivity of superordinate power and the tacit enabling of third parties.

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1. Khaled Khazziha and Mohammed Daraghmeh, “Israel Widens Gaza Bombing Targets, Deploys Ground Troops,” The Associated Press, July 12, 2014.

2. BBC News, “UN Calls for Israel-Gaza Ceasefire,” July 12, 2014.

3.U.S. Foreign Aid to Israel. Congressional Research Service report. April 11, 2013
4. Khaled Khazziha and Mohammed Daraghmeh, “Israel Widens Gaza Bombing Targets, Deploys Ground Troops,” The Associated Press, July 12, 2014.
5.Reuters, "In Gaza, No Safe Place For Civilians: UN," The World Post, July 22, 2014.
6. Ibid.
7. Associated Press, "Strike Near UN School in Gaza Leaves 10 Dead," The World Post, August 3, 2014.
8. Ibid.
9. Ibld.
10. Jaroslav Pelikan, Jesus Through the Centuries: His Place in the History of Culture (Harper and Row: New York, 1987), p. 171. See Augustine, City of God, 3.14; 12.22.

Russia’s Putin on National Sovereignty: Political Realism Undone?

On February 28, 2014, Ukraine’s UN Ambassador Yurly Sergeyev informed the Security Council that Russia had invaded the Crimean Peninsula, a semi-autonomous region of the sovereign state. Heretofore, in exchange for Ukraine giving up its nuclear weapons, Russia had agreed in a treaty to respect the territorial borders of the Soviet Union’s former republic. After briefly discussing whether Putin’s land-grab should have come as a surprise to the world, I take a critical look at the Russian president’s rationale for invasion. I argue that political realism (i.e., strategic interests of particular states being the signature feature of international relations) undergirds Putin’s geo-political view. This foundation is problematic as evinced by Putin’s inconsistencies on national sovereignty.

Coming on the heels of the Olympic games meant to showcase Russia to the world, Putin’s show of force must have come as a complete surprise to the world.[1] After all, on the day before the obviously-planned invasion, Vitally Churkin, Russia’s ambassador to the United Nations had dismissed with a burst of haughty laughter a journalist’s question on whether Russia was suddenly conducting its “military exercises” near Crimea as a cloaked precursor to invasion. Indeed, the diplomat even conveyed a sense of having been insulted by the very question! We, the rest of the world, were being played like a sleepy fiddle.

A day or two before the invasion, unmarked Russians brought in by bus (members of Putin’s favorite biker group being among them) took over the provincial legislature. Once the Russian thugs were in control there, the pro-Russian Crimean leader, Sergey Aksyonov, somehow found himself installed as the region’s ruler. He “returned the favor” by asking Putin for help in maintaining peace.[2] The two-step dance by the emperor and his aspiring governor-to-be resulted in a sham referendum quickly followed by a hasty annexation of Crimea as a region of Russia. The sheer speed of these events belied the veracity of the Russian narrative, a mere gloss for the de facto power of possession.

Speaking with U.S. President Barak Obama on the first day of the invasion, Putin stressed “the presence of real dangers to the lives and health of Russians who are currently present in the Ukrainian territory.” Putin stressed that Russia reserves the right to defend its interests and the Russian-speaking people who live in Ukraine.[3] Indeed, the Russian president claimed that Russia’s parliament had explicitly given him the right to intervene in Ukraine militarily. Meanwhile, Ukraine’s acting President Oleksadr Turchynov insisted that any reports of Russians and Russian-speaking Ukrainian citizens in the Crimean region being at all threatened were pure fiction, and thus merely a Russian front or subterfuge for raw military aggression.

Surely international law does not confer Russia, or any other sovereign country for that matter, with the right to invade (not to mention annex) other sovereign states simply because its ex-patriots may find their ethnicity is not fully protected; strategic geo-political interests of a state runs up against the doctrine of national sovereignty. Of course, this doctrine can give way, as a natural rather than state-sourced (and thus delimited!) right arguably exists to intervene across national boundaries if the systematic harm to inhabitants is sufficiently grave (e.g., the Nazi holocaust). As a likely subterfuge for taking the entire eastern half of Ukraine after having conquered Crimea, Putin attempted just this rationale. “If the Kiev government is using the army against its own people this is clearly a grave crime,” he said.[4] It would indeed be, were Ukraine’s government turning against ethnic Russians as Assad’s Syrian government had turned on protesters. Yet ironically Putin had vetoed efforts by the UN Security Council to sanction efforts to intervene in Syria, which unlike Ukraine could enjoy the absolutist variant of national sovereignty. Putin’s inconsistency on national sovereignty undercuts not only his credibility, but also that of his political theory of choice, political realism.

Being based on the primacy of a state’s power-interests, political realism implies a semi-permeable rather than absolutist rendering of national sovereignty. In his seventeenth-century masterpiece, Leviathan, Thomas Hobbes argues that a sovereign ruler should be given the power to do whatever he wants if peace is the aim. A century earlier, Jean Bodin also held an absolutist view of sovereignty, though unlike Hobbes, the sovereign is bounded by divine law while still ruling rather than only in divine judgment in the afterlife. So even within the absolutist camp, discernable differences exist (albeit premised on the belief in divine punishment—which held considerable sway in the sixteenth and seventeenth centuries).

Whereas the state that subscribes to political realism (i.e., the primacy of the country’s own interests) regards its national sovereignty as absolute (i.e., being invaded is not in the state’s geo-political interests), the story is quite otherwise with respect to the sovereignty of other countries (i.e., being invaded may be in the realist state’s interests). This inconsistency with respect to national sovereignty points to a fault-line running through political realism itself. 

At least in Russia's case, the absolutist interpretation is only to be selectively defended (i.e., when violating it is contrary Russia’s geo-political national interests), and with it the right to intervene in another country’s internal affairs. The oxymoron of a state-designated right being somehow valid beyond that state’s borders is itself indicative of the sheer incredulity of Putin’s stance. Perhaps the truly perplexing question bears on why the ruler of a modern empire would suppose that such logical problems can safely be dismissed. Perhaps the answer is that the world is all too willing to comply, being still too comfortable with antiquated ideas and ways.

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[i] See “The 2014 Winter Olympics in Russia: ‘Where There’s Smoke, There’s Fire.”

[ii] Chelsea Carter, Diana Magnay, and Ingrid Formanek, “Obama, Putin Discuss Growing Ukraine Crisis,” CNN, March 1, 2014.

[iii] Ibid.

[iv] Jacob Resneck and Olga Rudenko, “Putin Issues New Threat,” USA Today, April 25, 2014.