Historical Dictionary of Terrorism Third Edition

198 • FOURTH-GENERATION WARFAREDistrict Court for the Eastern Michigan District. The ruling foundthat the covert surveillance program violated not only FICA butalso the First and Fourth Amendments of the U.S. Constitution. Theadministration of George W. Bush had argued that warrantless wiretapsfor national security reasons were part of the “inherent powers”of the U.S. president’s office and that such warrantless surveillancehad been authorized by the Authorization for Use of Military Forceresolution passed by Congress following the World Trade Centerand Pentagon Attacks of September 11, 2001. While manycivil libertarians believe that FISA and other wireless surveillanceprograms implicitly violate the civil rights of U.S. citizens, JudgeRichard Posner of the U.S. Court of Appeals for the Seventh Circuitargued in an article, “A New Surveillance Act” (Wall Street Journal,15 February 2006), that FISA, even with the mentioned amendments,is insufficient for effective intelligence collection to prevent terrorismas it only permits surveillance of known terrorist individualsand groups, whereas effective intelligence gathering must be able toidentify previously unknown terrorist individuals and groups.FOURTH-GENERATION WARFARE. See ASYMMETRIC WAR-FARE.FRANCIA. The Front d’Action Nouvelle Contre l’Indépendence etl’Autonomie (New Action Front Against Independence and Autonomy)was a nonstate group of French settlers on the island of Corsicawith the limited aim of opposing the National Front for the Liberationof Corsica (FLNC). The group was formed in 1978 mainly ofFrench settlers displaced from Algeria. In 1979 it conducted about 40attacks against suspected FLNC members. In August 1980 a leader ofFRANCIA, Yannick Leonelli, was arrested.FRAPH. French acronym for Front Révolutionnaire pour l’Avancementet le Progrès Haitien, or Revolutionary Front for the Advancement andProgress of Haiti, a state-run death squad used to repress enemies ofthe military junta that overthrew President Jean-Bertrand Aristide in1991. When the junta, led by Lieutenant General Raoul Cédras, seizedpower, it organized the FRAPH movement in 1991 as a death squad fordealing with supporters of Aristide and anyone else who would opposetheir rule. FRAPH included various elements including members of theTonton Macoutes of the former ruling Duvalier family.