Say His Name: Police Brutality, Extra-Judicial Killings and Achieving Racial Justice in the American Legal System

Say His Name: Police Brutality, Extra-Judicial Killings and Achieving
Racial Justice in the American Legal System
Ritu Anovadiya 1
*I have not studied the American Legal System in depth.
EXPLICIT MATERIAL
Abstract
An analysis of the current situation in America following the death of George Floyd. This essay
will cover the issue of police brutality and what protesting against it really means. Veering on
the side of a legal analysis, I will look at the role of the American government in slavery and
the Jim Crow laws. I will also discuss how we can use legal and political reform to changes
things in the future. Restricting law enforcement in their use of force is not the only way in
which to tackle police brutality; we have to tackle the roots of racism. Racism is learnt and
once we understand that and make changes in the media and education systems, we will start
seeing changes. For my white friends, towards the end, I touch on understanding white
privilege and its use in advocating for change.
Introduction
D
espite the considerable efforts of creating unity and indivisibility in America, things have still not changed
for black Americans. 2 Although overt racism is rare, with the United States having ratified the International
Convention on the Elimination of All Form of Racial Discrimination (ICERD) in 1994, white supremacy
and separation still exists under the surface, being much harder to fight. It is disappointing to see we have returned
here. Police brutality has been a key issue in America for many years now, protests against it go back to the Civil
Rights era, and it still occurs. Most recently, 46-year-old George Floyd died in hospital
under police custody after being restrained by an officer. 3 Two officers had visited a store
having received a report of a forgery in progress. Floyd, unarmed, was parked a two-minute
walk away from the store. After being arrested, the officers noticed him going into medical
distress and called an ambulance. Despite this, we find footage of Floyd being held down by
three officers in handcuffs. Eventually, officer Derek Chauvin is shown kneeling on George
Floyd’s neck for more than eight minutes (fig 1). 4 The county autopsy report suggested that
he had died from a combination of heart disease and ‘potential intoxicants in his system’
that were exacerbated by the restraint, finding no evidence of strangulation or asphyxia.
However, a second autopsy was ordered by Floyd’s family attorney, Ben Crumb, stating that
‘We're not going to rely on this DA or this city to tell us the truth. We already saw the
truth…he has asthma, he had a heart condition - all these things that are irrelevant when
Figure 1: Floyd being restrained
by Chauvin
1
Brunel Law School Graduate. Email: anovadiyar@gmail.com.
2
Kevin E Jason, 'Dismantling the Pillars of White Supremacy: Obstacles in Eliminating Disparities and Achieving Racial Justice' (2020) 23 CUNY L
Rev 139.
3
Being so early, court documents have not been released, therefore the following has been acquired through news coverage.
4
Emmauelle Saliba, A Minute-To-Minute Breakdown Leading Up to George Floyd’s Deadly Arrest (May 30 2020, NBC News)
<https://www.youtube.com/watch?v=kiSm0Nuqomg> accessed May 30 2020.
1

they were living, breathing, walking, talking, just fine until the police accosted them’. 5 It was found in the private
autopsy that it was a homicide, that Floyd had no underlying conditions and that Floyd had died on the street after
four minutes of strangulation with the police still atop him. 6
Derek Chauvin has since been charged with third-degree murder and second-degree manslaughter. Under Minnesota
Law, murder in the third degree is ‘without the intent to effect the death of any person, causes the death of another by
perpetrating an act eminently dangerous to others and evincing a depraved mind, without regard for human life’. 7
Murder in the second degree, however, is where a person ‘causes the death of a human being with intent to effect the
death of that person or another but without premeditation’. 8 This seems more appropriate; Floyd on multiple
occasions pleaded with the police, telling them that he could not breathe and yet Chauvin persisted and applied more
force. Crump agrees that the sentence was not sufficient and is calling for the revision of the judgment to first-degree
murder; 9 the causation of death being ‘with premeditation and with intent to effect the death of the person or of
another’. 10 In the case of second or first-degree murders, there should also be the application of the aggravating factor
of racial discrimination. 11
George Floyd is far from alone; extra-judicial killings happen far too often. In
2019 there were only 27 days where the police had not killed someone. 12 These
killings disproportionately affect African Americans despite only making up 13%
of the population. African Americans are shot and killed by the police at a rate
that is over twice as high as for whites. 13
The Black Lives Matter movement was created and solidified in history by the
deaths of the following African American men;
Trayvon Martin (17), Eric Garner (43) and Michael
Brown (18). Most shocking was the death of Eric
Garner, who was put in a chokehold from behind by
Officer Daniel Pantaleo. This use of force is
prohibited by NYPD regulations (fig 2). Garner
Figure 2: Garner being choked by Pantaleo
expressed that he couldn’t breathe almost a dozen
times until he passed out on the street and died an hour later in the hospital. 14 The officer
was not charged for Garner’s death. 15
Figure 3: Sandra Bland mugshot
5
Les Steed, ‘George Floyd’s family hire own pathologist after autopsy finds he did NOT die of asphyxiation or strangulation by cop’ (30 May 2020,
The Sun) <https://www.thesun.co.uk/news/11744537/george-floyd-family-hire-pathologist-autopsy-finds-not-die-asphyxiation-strangulation-cop/>
accessed 30 May 2020.
6
Megan Sheets and Luke Kenton, ‘Coroner confirms George Floyd's death WAS a homicide as officials walk back initial reports he wasn't strangled
after family's autopsy found cop's knee on his neck caused asphyxia’ (1 st June 2020, The Daily Mail) <https://www.dailymail.co.uk/news/article-
8377809/George-Floyd-MURDERED-says-independent-autopsy-ordered-family.html> accessed 2 nd June 2020.
7
Minnesota Penal Code § 609.195.
8
Minnesota Penal Code § 609.19.
9
Steve Almasy and others, ‘Unrest mounts across multiple US cities over the death of George Floyd’ (30 May 2020, CNN)
<https://edition.cnn.com/2020/05/29/us/minneapolis-george-floyd-friday/index.html> accessed 30 May 2020.
10
Minnesota Penal Code § 609.185 .
11
Minnesota Penal Code § 244.10, Subd. 5a(11).
12
https://killedbypolice.net/
13
Niall McCarthy, ‘U.S Police Shootings: Blacks Disproportionately Affected’ (28 May 2020) Statista <
https://www.statista.com/chart/21857/people-killed-in-police-shootings-in-the-us/> accessed 30 May 2020.
14
https://cases.open.ubc.ca/black-lives-matter/
15
Katie Benner, ‘Eric Garner’s Death Will Not Lead to Federal Charges for NYPD Officer’ (16 July 2019, The New York Times)
<https://www.nytimes.com/2019/07/16/nyregion/eric-garner-case-death-daniel-pantaleo.html> accessed 30 May 2020.
2

Women are not safe either. The death of Sandra Bland (fig 3) is another example. In 2015, Bland had a ‘confrontation’
with Officer Brain T. Encinia at a traffic stop which led to her being arrested on a charge of assaulting a public servant.
Encinia claimed that his ‘safety was in jeopardy at more than one time’, 16 a video taken by Bland herself of the arrest
indicated no behaviour whatsoever that would reasonably cause such fear. 17 Cannon Lambert, the Bland family
attorney, agreed. 18 Three days later, she was found hanging in her cell. 19 The injuries found in the autopsy of Ms Bland
were consistent with suicide, lacking signs of a violent struggle. The issue here was the seemingly intentional
negligence as Bland was not placed on suicide watch. At the time of entering the jail, she had informed the police that
she had once tried to kill herself after a miscarriage, that she had battled depression and that she was feeling depressed
at the time. Curiously, hours later, another questionnaire was filled out that claimed that Sandra Bland had never been
depressed, nor was she depressed at that moment, although it did mention her previous attempt on her life. Encinia
was only charged for perjury, committed if one ‘makes a false statement under other or swears to the truth of a false
statement previously made and the statement is required or authorized by law to be made under oath’. 20 This would
have carried the sentence of a year in jail and a $4,000 fine. 21 All charges were dropped after Encinia agreed to give up
his police license and never seek another job under law enforcement. The Sandra Bland case was not sentenced
correctly, this was not a simple case of false statements but a case of neglect with the result of death, which should
have been considered. As well as this, considering the social context of the death of Ms Bland, more should have been
done. Bland taking her life was a very real possibility that the reasonable person would have seen. This was a case of
manslaughter, a second-degree felony in the state of Texas, 22 with a sentence of 20-2 years jail time with the fine that
will not exceed $10,000. 23 The injustice here made this case a turning point in the Black Lives Matter movement
Cases are mounting, on the 27 th of May 2020, Emerald Black, a visibly pregnant black woman was pulled from her car
by California officers for ‘bad registration tags’, despite asking to stay seated in the vehicle. 24 Her doctor had informed
her earlier in the day that she was at a high risk of miscarriage. 25 Regardless, the officers ‘yanked Ms Black from the
car, taunted her, piled on top of her and stomped on her stomach, leaving a shoe mark’. Black had a miscarriage three
days later. She had not committed any crimes and was simply the passenger of the car, yet they treated her like she had
committed a violent felony. 26 This is identical to another case in 2014 where a woman claimed that New York City
officers ‘battered’ her during an unlawful search and seizure, leading to a miscarriage. 27 To go through all the most
distressing cases would be an endless task, but the cases above should illustrate how dire the problem is. 99% of
killings by the police from 2013-2019 have not resulted in officers being charged. 28 Things need to change, and they
need to change now, but that is more easily said than done. The fight for freedom did not end when slavery was
abolished, it did not end with the Civil Rights Movement. This is barbaric and must be treated as such.
16
David Montgomery, ‘The Death of Sandra Bland: Is There Anything Left to Investigate’ (May 8 2019, The New York Times)
<https://www.nytimes.com/2019/05/08/us/sandra-bland-texas-death.html> accessed 30 May 2020.
17
<https://www.youtube.com/watch?v=aGnENyG3Aq4> accessed 30 May 2020.
18
David Montgomery, ‘Sandra Bland, It Turns Out, Filmed Traffic Stop Confrontation Herself’ (May 7 2019, The New York Times)
<https://www.nytimes.com/2019/05/07/us/sandra-bland-video-brian-encinia.html> accessed 30 May 2020.
19
n 15.
20
Texas Penal Code § 37.01(1)
21
ibid
22
Texas Penal Code § 19.04 (b)
23
Texas Penal Code § 12.33 (b)
24
NOTE: This is a pending law suit, all facts have not been found.
25
Paul Blest, ‘A Pregnant Black Woman Miscarried After California Police Allegedly ‘Stomped’ on Her Stomach’ (May 27 2020, Vice News) <
https://www.vice.com/en_us/article/5dzbyb/a-pregnant-woman-miscarried-after-california-police-allegedly-stomped-on-her-stomach> accessed 30
May 2020.
26
ibid
27
Frank Donnelly, ‘Lawsuit: Woman miscarried after cops 'battered' her during 'false' arrest’ (1 February 2016)
<https://www.silive.com/northshore/2016/02/lawsuit_woman_miscarried_when.html> accessed 30 May 2020.
28
< https://mappingpoliceviolence.org/> accessed 30 May 2020.
3

History of Racial Discrimination and the Development of Laws in America
B
lack people in America have faced countless challenges; the greatest and longest being slavery. Contrary to
popular belief of the first enslaved Africans arriving in the US in 1619, in 1565, the Spanish brought enslaved
Africans to present-day St Augustine 29 and even earlier in 1526 the Spanish had a failed expedition to presentday
South Carolina when the enslaved resisted. 30 Slavery was abolished in 1865 through the ratification of the 13 th
Amendment of the US Constitution. It is easy to forget the severity of racism in America; school textbooks fail to
capture the gravity of the situation; it is made to seem so far in the past. The teaching of
racism after the abolition of slavery is particularly poor, which breeds ignorance. I will
attempt to offer an unvarnished account of certain occurrences I believe have not been
paid enough attention. The following is only a snapshot of the brutality of slavery.
It is estimated that 1.8 million died in slave ships (many sick were also thrown overboard
as sick slaves sold for less and insurance companies paid for lost slaves 31 ) after being
forcefully taken from their homes and families and 10.6 million became slaves on
plantations in the American South or the Caribbean. 32 Many slave owners argued that the
enslaved benefitted from removal from Africa. This is false; the average life expectancy of
on plantations was a mere 7-9 years. 33 Half of all enslaved children died before the age of
two. From birth, the average life expectancy was 21-22 years, compared to the 40-43 years
that whites lived. 34 Working days on the plantations were long, up to 18 hours a day and
punishment was severe. Whipping (fig 4), branding, mutilation and even death was used
as punishment for misbehaviour (e.g. not working hard enough). Mingo White described
the beating of a slave caught praying for freedom:
Figure 2: Peter, an escaped slave at a
medical examination in Baton Rouge,
Louisiana, 1863 displaying his scars.
‘Ned was made to pull off ever’thing but his pants an’ lay on his stomach ‘tween de
pegs whilst somebody stropped his legs an’ arms to de pegs. Den dey whipped him
‘twell de blood run from him lack he was a hog.’ 35
Figure 5: Punishment of being hung by
the ribs. This man stayed alive for 3 days
before being clubbed to death after
insulting a guard.
Another described slave owner Ben Heard giving as much as 500 strikes with a whip
followed with no medical attention; they would have to go straight back to work. 36
Perhaps the most horrifying account of ill-treatment concerned slave owner Madame
Lalaurie. Despite having her slaves sold on after being found guilty for abuse, her
relatives bought the same slaves and returned them to her. It was known that she had
chained them to the walls of her home, but this did not cause alarm. However, on the
10 th of April 1834, one of her slaves managed to set fire to the house. 37 Reporters
from The New Orleans Bee described that ‘upon entering one of the apartments, the
most appalling spectacle met their eyes. Seven slaves more or less horribly mutilated
29
<http://www.americaslibrary.gov/jb/colonial/jb_colonial_augustin_2.html> accessed 2 June 2020.
30
Michael Guasco, ‘The Misguided Focus on 1619 as the Beginning of Slavery in the U.S. Damages Our Understanding of American History’ (13
September 2017) Smithsonian Magazine < https://www.smithsonianmag.com/history/misguided-focus-1619-beginning-slavery-us-damages-ourunderstanding-american-history-180964873/>
accessed 31 May 2020.
31
Gregson v Gilbert [1783] ruled the practice legal.
32
https://www.haaretz.com/.premium-from-freedom-to-slavery-1.5245587?v=1590943725509
33
http://abolition.e2bn.org/people_27.html
34
http://www.digitalhistory.uh.edu/disp_textbook.cfm?smtID=2&psid=3040
35
Image 416, Federal Writers' Project: Slave Narrative Project, Vol. 1, Alabama, Aarons-Young, 1936-1937
36
ibid, Image 154
37
Judith K Schafer, ‘Details Are of a Most Revolting Character: Cruelty to Slaves as Seen in Appeals to the Supreme Court of Louisiana -
Symposium on the Law of Slavery: Criminal and Civil Law of Slavery’ (1993) 68 Chicago-Kent Law Review 3, 1287.
4

were seen suspended by the neck, with their limbs apparently stretched and torn from one extremity to the other. The
slaves were the property of the demon, in the shape of a woman’ 38 Another harrowing case was reported by a British
military officer where a woman began beating an enslaved woman with the heel of her shoe until ‘it was almost all of a
jelly’. The woman then threw the enslaved woman on the ground and stomped on her head until her now severely
disfigured head became to slip through a hole in the ground. 39 State v Morris 40 was, however, the first appeal for a
criminal conviction for cruelty to a slave. 41 The defendant had beaten his slave ‘in a cruel and barbarous manner…
causing sundry dangerous and severe bruises and wounds upon the thigh, loins, and other parts of the body. A hole in
the abdomen, the size of a dollar which appeared to have been gouged out’ was the immediate cause of death. 42 Morris
was found guilty; this is a rare result.
It is important, before attempting to analyse contemporary law to note that the American legal system, much like the
British legal system, was designed to subjugate. The American Constitution does not mention slavery until 1865 with
the adoption of the 13 th Amendment and yet is riddled with provisions protecting slavery without making explicit
mention of it. 43 The ‘Against Runaway Servants’ Act 44 was the first clear reference to slavery. The act punished
runaway servants by extending servitude and branding them. It was in 1659-60 that Virginia first recognised slavery,
considering Africans to be property or ‘things’ rather than persons. 45 In 1661, Virginia passed its first police regulation
of slaves, particularly tackling the problem of European servants escaping with slaves. The first significant piece of
legislation related to the children of white men and African women as under the common laws at the time, the status
of a child born out of wedlock followed the status of the father meaning these children would be born free. The 1662
statute solved this issue for white male slave owners who wished to still have sex with African women, stating ‘that all
children borne in this country shall be held bond of free only according to the condition of the mother’. 46 Another law
excused owners from liability if a slave died from punishment: ‘it cannot be presumed that prepensed malice…should
induce any man to destroy his own estate’. 47 A law of 1680 further limited the protection of the common law by
making it legal to kill any escaped slaves. 48 Most significant was the ‘Gag Rule’ passed during the 24 th Congress which
prohibited the House of Representatives from considering anti-slavery petitions (finally ruled unconstitutional in 1844
by John Quincy Adams). 49 These are just some examples of the law enforcing slavery. America, along with many other
nations, is built on the blood of slaves.
After the end of the American Civil War, the famous 13 th Amendment was ratified along with the 14 th and 15 th
Amendments. The 14 th Amendment granted citizenship to all persons born or naturalized in the US, including former
slaves and the 15 th Amendment granted the right to vote irrespective of race, colour, or previous condition of
servitude. African Americans were free and they were citizens. These amendments of the US Constitution brought
about the Reconstruction Period which sought to bring the nation back together, bringing hope to African Americans
(note however that Mississippi did not ratify the 13 th Amendment outlawing slavery until 1995). A significant program
38
The New Orleans Bee, April 11-12 Issue, 1834.
39
Marisa Joanna Fuentes, ‘“Buried Landscapes: Enslaved Black Women, Sex, Confinement and Death in Colonial Bridgetown, Barbados and
Charleston, South Carolina’ (2007) PhD, University of California, Berkeley.
40
State v Morris 4 La. Ann 177 (1849).
41
n 35
42
ibid, State v Morris
43
Paul Finkelman, ‘Slavery in the United States: Persons or Property?’ (2012)
44
‘Against Runaway Servants’ Act XVI, March, 1657–58, 1 Hening 440.
45
‘An Act for the Dutch and all other Strangers for Tradeing to this Place’ Act XVI, March,
1659–60, 1 Hening 540.
46
‘Negro womens children to serve according to the condition of the mother’, Act XII, December
1662, 2 Hening 170. Emphasis in the original. (NOTE: Slave fathers had no control of their children regardless)
47
‘An act about the casuall killing of slaves’, Act I, October 1669, 1 Hening 270.
48
Act X, June 1680, 2 Hening 481.
49
<https://history.house.gov/HistoricalHighlight/Detail/35837> accessed 3 June 2020
5

was the Freemen’s Bureau which worked to educate former slaves and assistant them in adjusting to living free. These
victories were short lived, many states enacted various ‘Black Codes’ to again oppress the black community.
Florida was the most ‘bigoted and short-sighted of all southern
legislature of 1865-1866’. 50 A Florida Supreme Court justice told the
legislator which passed the codes: ‘we have a duty to perform – the
protection of our wives and children from threatened danger, and the
prevention of scenes which may cost the extinction of an entire race’. 51
Black Codes only referred to black people (anyone with one-eighth or
more black blood 52 ), and in general treated them as inferior, little more
than subordinate labourers. 53 To ensure they would be good labourers,
a special ordinance was passed for a vagrancy law meaning that any ablebodied
person who was ‘wandering or strolling about or leading an idle,
profligate, or immoral course of life’ could be arrest upon complaint of
any citizen. 54 Penalties for all crimes included imprisonment, whipping,
fines and being sold to the highest bidder for as long as 12 months. 55
Inciting of insurrection, administering poison, burglary and rape of a
white woman however was punishable by death. 56 To illustrate the
excessive sentences during this
Figure 6: 1920 Duluth Lynchings
period, there was a certain case
of a freedman being sold for 40 days for taking a log out of the river and selling
it. 57 However, the federal government did soon intervene and outlawed the use
of whipping and declared it unconstitutional to prohibit the bearing of arms. It
was also warned that there must be no difference before the law based on
colour. 58
Figure 7: Lynching of Laura Nelson. Oklahoma,
1911
Then came the rise of the Ku Klux Klan (KKK) which by 1870 had become a
vehicle for white resistance to the Reconstruction policies which ended the
Black codes. The early 20 th century saw a surge in KKK activity including
bombings of black schools and churches and violence against black and white
activists. 59 Lynching (not exclusively practised by the KKK) during this time
was a huge problem, from 1882-1968, 4,743 lynchings occurred across the US
with 72.7% of the victims being black. 60 Many whites felt that African
Americans were getting away with too much freedom. Lynchings were done
under the name of justice; for example, in the case of Will Brown (fig 8), he
was alleged to have raped a 19-year-old white girl. In another case, three
50
Joe M. Richardson, ‘Florida Black Codes’ (1969) 47 The Florida Historical Quarterly 365, 372.
51
Patrick. ‘Reconstruction of the Nation’ (1865-1866) 34 Florida House Journal 64.
52
n 50, 374.
53
ibid 366.
54
ibid 371.
55
ibid 372.
56
ibid 374.
57
C. M. Hamilton to McHenry, March 31, 1866, Bureau Records, Florida.
58
n 50, 377.
59 <https://www.history.com/topics/reconstruction/ku-klux-klan> accessed 3 June 2020
60
<https://www.naacp.org/history-of-lynchings/> accessed 3 June 2020
6

Figure 8: The burnt corpse of Will Brown
African American circus workers (fig 6) were suspects in an
assault case. The case of Mary Turner was particularly
horrifying. Her husband had shot and killed abusive plantation
owner Hampton Smith resulting in a manhunt for him. Mary
denied his involvement. Not long after, on the 19 th of May
1918, a mod of several hundred came, tied her ankles, hung
her upside down from a tree, doused her in gasoline and set
her on fire. While she was still alive, her abdomen was cut
open with a knife, and her unborn child fell out on the
ground. The baby was stomped on and crushed. 61 When
considering that the great majority of victims were black, it is
clear to see that lynching had little to do with justice. Even
more shockingly, lynching was only just recognised as a
deprivation of civil rights in 2018. The Justice for Victims of
Lynching Act of 2018 further acknowledged that 99% of all
perpetrators have escaped punishment from the State. 62
Next, I would like to bring attention to the Jim Crow laws, which found its roots in the Black Codes. Note that
lynching was practised before and during these laws. These laws began to be enacted in 1877 when the Supreme Court
ruled in Plessy v Ferguson that it cannot prohibit segregation, identifying with the principle of ‘separate but equal’. Jim
Crow laws were state and local laws that enforced racial segregation. Public parks were forbidden for African Americans
to enter, and theatres and restaurants were segregated. Segregated waiting rooms in bus and train stations were
required, as well as water fountains, building entrances, elevators and cemeteries. 63 Segregation even extended to
schools, phone booths, hospitals, asylums, jails, prostitutes, 64 school textbooks. Atlanta gave African Americans a
different Bible to swear on. Marriage between whites and blacks was forbidden.
The Civil Rights Movement
What followed the Jim Crow laws was the Civil Rights Movement, which started in the late 1940s and ended in the
late 1960s, that we know so well. Although Brown v Board of Education repealed the decisions made in Plessy,
effectively ending racial segregation in public schools, many schools remained segregated. This also did not extend to
other areas of society and thus started the protesting led by the figures that changed the world: Rosa Parks, Martin
Luther King Jr, Malcolm X and many more. September of 1957 saw the signing of the Civil Rights Act 1957 which
allowed for federal prosecution of those who suppressed another’s right to vote. In 1964, President Lyndon B Johnson
signed the Civil Rights Act, which legally ended the segregation laws that Jim Crow laws had institutionalised. Lastly,
the Fair Housing Act of 1968 ended discrimination in the renting and selling of homes. Looking at the history of
racism in America is appalling, to put it mildly. No legal change came without years of protesting.
The American Legal System purports to protect its citizens, but this is far from the truth and is still the case. It was
only in 2017 that the US condemned ‘hate crime and any other form of racism, religious or ethnic bias, discrimination,
incitement to violence, or animus targeting a minority in the United States’. 65 This is not surprising when we look at
the immoral foundations upon which the nation is built. Although the US has reformed its laws, what remains clear
61
ibid
62
Justice for Victims of Lynching Act 2018, s2(5).
63
<https://www.history.com/topics/early-20th-century-us/jim-crow-laws#section_1> accessed 3 June 2020.
64
In New Orleans
65
Senate Resolution 118, 115 th Congress, April 5 2017
7

from police brutality cases today is that things have not changed, and the justice system has failed. Today, we struggle
with structural racism, and this is something that has not been tackled successfully by the State. The purpose of this
section was to set the tone for the rest of the essay. We are not seeking justice for one incident; we are fighting against
this violent history of racism upon which these biases exist. The fact that the State is not openly making efforts to deal
with police brutality shows that nothing has changed, and the justice system is still racist, endorsing white supremacy.
Acknowledging the Past
O
ther than the criminal justice system failing to protect the black community, there has also not been
sufficient attention brought to the acts of racism in America’s past, which I believe has only worsened the
situation. It is true that those who do not remember the past are doomed to repeat it. America and Britain
have done the minimum needed to accept the events but not trying to bring attention to the crimes against humanity
that occurred. Most of the emphasis is based on the efforts of activists during the Civil Rights Movement and not
enough placed on the crimes themselves; the acts of brutality. While this is a social problem, the State has not worked
hard enough with political policies to tackle the issue and bring attention to racism.
Steve McQueen, director of movie 12 Years a Slave, points out the ignorance of slavery well; ‘The Second World War
lasted five years, and there are hundreds of films about [that] and the Holocaust. Slavery lasted 400 years, and yet there
are less than 20 films about slavery in North America’. 66 The Holocaust of WWII had a death toll of 6 million; granted
the slave trade does not reach the same death toll, but the 10 million tortured souls make it a sound point of
comparison. 67 The Holocaust alone brought about the United Nations Charter, the foundation for all human rights
across the globe, it is arguably the most important document to have ever been created. To illustrate further, there are
84 Holocaust museums and memorials in America, and
there are 7 dedicated to slavery. Alternatively, 53 if we
include those dedicated to Malcolm X and Martin
Luther King Jr. Even more worryingly, after the Civil
War ended, Southerners who supported slavery so
fiercely attempted to create a narrative filled with happy
enslaved Africans, this was depicted in many monuments
(fig 9), nearly all of which still stand today. 68 Loyal-slave
stories hides the brute force used to keep the enslaved in
Figure 9: The Confederate Monument at Arlington National Cemetery depicts a
black enslaved woman holding a white baby, her face streaked by a tear as her
enslaver heads off to war.
line, easing the conscience of white Southerners.
Marcus Rediker, author of The Slave Ship: A Human
History points out that slavery will never be treated like the Holocaust ‘because the majority of the white population is
utterly opposed to reparations and would not like to remember slavery in any way that might lead to economic and
political conclusions. The difference is that the people who want to remember in Israel are in charge of the
government’. 69 It took until 2007-9 for Virginia, seven other states and the US House and Senate to apologise for their
roles in perpetuating the institutions of slavery and/or Jim Crow. 70 Arkansas, New Jersey and the US Senate included
66
Ben Child, ‘Steve McQueen accuses film industry of ignoring slavery’ (3 January 2014, The Guardian)
<https://www.theguardian.com/film/2014/jan/03/steve-mcqueen-slavery-12-years-a-slave> accessed 30 May 2020.
67
This does not disregard the gravity of the events of WWII, it is just the only similar event where the key variable to have changed is the race of its
victims.
68
Kali Holloway, ‘”Loyal Slave” Monuments Tell a Racist Lie About American History’ (25 March 2020, The Nation)
<https://www.thenation.com/article/archive/loyal-slave-confederate-monuments-civil-war-slavery/> accessed 2 nd June 2020.
69
P. R. Lockhart, ‘America is having an unprecedented debate about reparations. What comes next?’ (20 June 2019, Vox)
<https://www.vox.com/identities/2019/6/20/18692949/congress-reparations-slavery-discrimination-hr-40-coates-glover> accessed 30 May 2020.
70
Angelique M Davis, ‘Apologies, Reparations, and the Continuing Legacy of the European Slave Trade in the United States’ (2014) 45 Journal of
Black Studies 271, 273.
8

disclaimers in their apologies that they could not be used to support reparations claims or other compensatory
measures. 71 However, as recognised by Barack Obama during his elections, ‘the best reparations we can provide are
good schools in the inner city and jobs for people who are unemployed’. 72 Apologies are necessary, however, in
addition to reparations as denying apologies absolves whites and the state of their roles in the institution of slavery.
John Conyers first proposed a bill to have a commission study slavery and its effects and develop reparation proposals
for African Americans 73 in 1989. The bill was consistently voted out. However, Conyers persisted and proposed the bill
every year until the year of his retirement, 2017. The bill was reintroduced again in 2019 by Ms Jackson Lee. This is
just one illustration of the State refusing to take responsibility. It can be argued that governments of today should not
have to pay for the original sins of the past; however, this is far from the truth, the scars of slavery are still seen
today. 74
The legacy of slavery and the Jim Crow laws continue and has directly impacted racial inequalities. Michael Dawson,
Political Science Professor at the University of Chicago, found that 71% of African Americans supported slavery
reparations while only 3% of the white people did. 75 Many people chalk down the denial of the reparations argument
to finances, not to race, these results show that this is not the case, if it was, both figures would be much closer
together. African Americans should not simply ‘get over it’ as Senator Sam Brownback suggested. 76 How can you get
over something that still significantly hinders every aspect of your existence today? Professor Ogletree argues that ‘an
essential element of the process of reparations is recognising that the present is not an accident or fortuity’. 77
Institutionalised Racism
T
o think that we have moved past racism is false. Systemic or institutionalised racism refers to the idea that
white superiority is found in everyday thinking and governs our institutions or systems. It is impossible to
detect when looking at a one on one interactions but is blindingly clear when looking at the bigger picture.
This also relates to my later discussion on white privilege, which you cannot detect without taking a step back and
looking at the statistics. Stokely Carmichael and Charles V Hamlinton explain the concept well:
‘When a black family moves into a home in a white neighbourhood and is stoned, burned or routed out,
they are victims of an overt act of individual racism which most people will condemn. But it is
institutional racism that keeps black people locked in dilapidated slum tenements, subject to the daily
prey of exploitative slumlords, merchants, loan sharks and discriminatory real estate agents. The society
either pretends it does not know of this latter situation, or is in fact incapable of doing anything
meaningful about it’ 78
The economic impact of racism is one of the worst; immobilising minorities. A Harvard study found that job
seekers were more likely to get interviews if they ‘whitened’ their names. With applications that implied their
race, 10% of black candidates got interview offers whereas when ‘whitening’ their CV’s, 25% got interviews. 79
You are more than twice as likely to get a job if you are white. What’s more, ‘pro-diversity’ employers (those
71
ibid
72
ibid
73
H. R. 4, 115 th Congress, 1 st Session.
74
ibid 70
75
n 72, 279.
76
ibid 280.
77
ibid 282.
78
Stokely Carmichael, Charles V. Hamilton, Black Power: The Politics of Liberation (Vintage, 1992).
79
Dina Gerdeman, ‘Minorites Who ‘Whitened’ Job Resumes Get More Interviews’ (2017) <https://hbswk.hbs.edu/item/minorities-who-whitenjob-resumes-get-more-interviews?cid=spmailing-25757313-WK%20Newsletter%2004-03-2019%20(1)-April%2003,%202019>
accessed 3 June
2020.
9

who claim equal opportunities and encourage minorities to apply) discriminate the same amount as those who
do not mention diversity at all in job adverts. 80 The difference is that minorities are more likely to put their
guard down and state their race, only to be at a greater risk of discrimination. In turn, this contributes to the
wealth gap. In 2010, the median net worth for a white family was $134,000, whereas an African American
family had a median of $11,000. The median wealth for a single white woman was $41,000, whereas, for African
American woman, the median was $120. 81 Another big issue is housing discrimination, something the current
President, Donald J Trump, was found guilty of. 82 African Americans are denied mortgages at drastically higher
rates than their white peers; they are three times more likely to be rejected. The gap between black ownership
(44%) and white ownership (69%) is worrying. 83 In terms of rent, minorities are more likely to have higher
payments, and when looking for houses, real estate agents, and rental housing providers recommend and show
fewer available homes to minorities than equally qualified whites. 84 These are just some of the more important
illustrations of systemic racism but there many more.
The Problem with Racial Diversity
The role of the media is mammoth in the maintenance of racism, containing countless underlying messages that
people of colour are lesser. As stated by the European Research Centre on Migration and Ethnic Relations, 85 the mass
media has an ‘unequivocal position in society when it comes to establishing and disseminating common cultural
references. The mass media have an influence on people's attitudes as well as our common knowledge, but not always
in the expected and desired ways’. Within the media, there is always a lack of representation for racial minorities; if you
were to turn on the television right now, it is almost guaranteed that you will be met with a white person. In a
television show or a movie, the lead will never be a person of colour, a sidekick figure at the very most. In 2019, only
27.6% of movies in the United States had minority lead actors with 72.4% being white. 86 Even more worryingly, there
is never a children’s book where the main characters are not white; Harry Potter comes to mind here, and I will use
this as an example. Only 7% of children’s books published in Britain in 2018 had a character of colour. 87 The problem
is that young people, in particular, absorb these subliminal messages. It makes it hard for a child of colour to picture
themselves in the position of their favourite heroes, accepting that they will never be like them. That they will never
amount to the same level of success. The attitude when you’re young is that if society clearly thinks that then it must
be true. They will not be able to see the racist undertones to the choices of the race of main characters. A study on the
representation of race in children’s picture books showed that children often do not take a critical stance when reading
a text, simply not recognising the different cultures in text. Children passively absorb the messages. Without an
understanding of the deeper messages in the lack of racial representation and the fact that this is wrong, the minds of
children are damaged from young ages. Equally, it also breeds racism and prejudice with white children seeing
80
ibid
81
<https://www.raceforward.org/videos/systemic-racism> accessed 2 June 2020.
82
Josh Gerstein, ‘ FBI releases files on Trump apartments' race discrimination probe in '70s’ (2017, Politico)
<https://www.politico.com/blogs/under-the-radar/2017/02/trump-fbi-files-discrimination-case-235067> accessed 3 June 2020; Jonathan Mahler and
Steve Eder, ‘”‘No Vacancies” for Blacks: How Donald Trump Got His Start, and Was First Accused of Bias’ (27 August 2016, The New York Times)
<https://www.nytimes.com/2016/08/28/us/politics/donald-trump-housing-race.html> accessed 3 June 2020.
83
Keeanga-Yamahtta Taylor, ‘Housing market racism persists despite ‘fair housing’ laws; (24 January 2019, The Guardian)
<https://www.theguardian.com/commentisfree/2019/jan/24/housing-market-racism-persists-despite-fair-housing-laws> accessed 3 June 2020.
84
Margery Austin Turner and others, ‘Housing Discrimination against Racial and Ethnic Minorities 2012: Full Report’ (2013, Urban Institute)
<https://www.huduser.gov/portal/Publications/pdf/HUD-514_HDS2012.pdf> accessed 3 June 2020.
85
Jessika ter Wal (eds), ‘Racism and Cultural Diversity in the Mass Media: An overview of research and examples of good practice in the EU
Member States, 1995-2002’ (2002)
86
Amy Watson, ‘Distribution of Lead Actors in Movies in the United States from 2011 to 2019, by Ethnicity’ (2020)
<https://www.statista.com/statistics/696850/lead-actors-films-ethnicity/> accessed 3 June 2020.
87
Centre for Literacy in Primary Education, ‘Announcing Reflecting Realities 2019: the CLPE’s second survey into ethnic representation in UK
Children’s Literature’ (2019) <https://clpe.org.uk/aboutus/news/announcing-reflecting-realities-2019-clpe%E2%80%99s-second-survey-ethnicrepresentation-uk>
accessed 3 June 2020.
10

themselves as superior, leading figures in every narrative. 88 Personally, as a young Harry Potter fan, my favourite
character was Hermione, but I accepted that I would never be like her. The characters I was left to see myself, as an
Indian girl, were the Patil sisters, depicted as particularly annoying and unattractive. Harry Potter being one of the
most prominent influences in my life, I accepted that view of Indian women and saw myself in the same way.
Recently, there has been a lot of activism in the modelling industry about photoshopping imperfections such as stretch
marks from models and the lack of plus-size models. The detrimental effects of this were recognised and instantly
rectified. Now we see a flood of commercial models showing these imperfections and several plus-size models have
been pushed into the spotlight. With 78% of models in fashion adverts being white 89 if even half the effort put into
this movement was put into getting people of colour on billboards, magazines and advertisements, we would be in a
better position. Supermodel Naomi Campbell reflected on her experiences as a black woman in the modelling industry:
‘When I started out, I wasn’t being booked for certain shows because of the colour of my skin. I didn’t let it rattle me.
From attending auditions and performing at an early age, I understood what it meant to be black. You had to put in
the extra effort. You had to be twice as good.’ 90 Not only is it hard to get in the industry, with the lack of
representation, coloured women who are interested in the career will never even try.
The lack of racial diversity is much more damaging than it seems on face value. It passes on the message that to be
white is to be beautiful. I have always been under the impression that my brown skin is not beautiful, accepting it as a
part of life. I still struggle with it as an adult who understands that this is far from the case, it is hard to ignore when
all you see is white skin being celebrated. These racist messages are powerful, changing your thoughts and feelings in a
way that is hard to detect, especially when young. The lack of representation is a considerable problem and works to
maintain systems of racism in the world; large corporations can make differences and governments must ensure this
happens. While it will appear forced to adults, as current efforts to improve racial diversity have been, children will at
least accept the new representations of people of colour. With time it will become more natural to see a person of
colour when you turn on the television.
Legal and Political Policies for Change
W
hen looking at ways in which we can reform the system, we have to first accept that racism does exist,
police do have biases and will racially profile citizens. This is a fact, and we have seen it time and time
again. Changing these biases is a question of creating social change and dedicating ourselves to activism
but there are things to be done on a legal level.
Concerning the criminal justice system there firstly needs to be tighter regulations on the use of force. The Use of
Force Project looks at the effectiveness of use of force policies on reducing police brutality. They found that police
departments with four or more restrictive use of force policies had the fewest killings per population; each additional
use of force policy was associated with a 15% reduction in killings by police. 91 Compared to police departments with
no policies, those who used every single restriction on the use of force had 72% less killings. Police organisations have
opposed these measures claiming that it puts communities at risk, however, the Project also found that department
88
Sade Popoola, ‘A Critical Reading of the Impact of Racial Representation within Children’s Books’ (24 March 2019)
<https://medium.com/@sadep79/a-critical-reading-of-the-impact-of-racial-representation-within-childrens-books-c4cc08e502e5> accessed 3 June
2020.
89
Priya Elan, ‘Survey finds that 78% of models in fashion adverts are white’ (10 May 2016, The Guardian)
<https://www.theguardian.com/fashion/2016/may/10/survey-finds-that-78-of-models-in-fashion-adverts-are-white> accessed 3 June 2020.
90
Naomi Campbell, ‘Naomi Campbell: ‘At an early age, I understood what it meant to be black. You had to be twice as good’ (19 March 2016, The
Guardian) < https://www.theguardian.com/fashion/2016/mar/19/naomi-campbell-modelling-bob-marley-putin-autobiography-extract> accessed 3
June 2020.
91
<http://useofforceproject.org/#analysis> accessed 3 June 2020.
11

with more restrictive policies had fewer officers killed in the line of duty. 92 Moreover, it found that departments with
restrictive policies have similar crime rates as those with less stringent policies.
Secondly, to aid social change, there should be more done about systemic racism. The state must not ignore that there
are differences in treatment. There must be legislations first to improve racial diversity and representation in the media,
specifically children’s material. While it is in the hands of producers of these goods, the government must enforce the
duty with criminal sanctions; for example, there must be a minimum number of ethnic minorities appearing in
magazines. As well as this, there should be closer investigations into all companies, looking at both the treatment of
their workers and their hiring practices. Although legal enforcement of these rules seems excessive, as simply urging
businesses to comply has not worked, stricter measures must be taken. The state has no problem giving peaceful
protestors criminal sanctions, why not the same excessively strong hand concerning discrimination? There is no excuse
for people of colour in 2020 to have their lives undervalued continuously. The bill for the study of slavery and its
reparations must also be passed. Perhaps money does not need to be paid if finance is such a problem, but much more
additional support must be given.
Thirdly, there needs to be a closer look at the sentencing practices of each state. Sentences often fall heavier on African
Americans, and this is no coincidence, people have lost their faith in the police force and rightly so. Professor Mark
McCoy recently tweeted: ‘George Floyd and I were both arrested for allegedly spending a counterfeit $20 bill. For
George Floyd, a man my age, with two kids, it was a death sentence. For me, it is a story I sometimes tell at parties’. 93
He went onto explain that he had told the cops that he didn’t eat his dinner before getting arrested, the officer said he
couldn’t take the cuffs off but proceeded to laugh and spoon feed him his dinner. The biased criminal convictions are
also seen in criminal cases on police officers guilty of brutality. As mentioned before, 99% of killings by the police
from 2013-2019 have not resulted in officers being charged with crimes. 94 African Americans are more likely to be
arrested and when arrested, more likely to be convicted. African Americans are 5.9 times more likely to be incarcerated
than whites. Even further, as of 2001, one of every three black boys born in that year can expect to go to prison in his
lifetime, compared to one of every seventeen white boys. 95
Moving Forward Socially
T
here are ways in which we can push forward change which will bring about the criminal justice system
reforms we need. We begin with education; knowing what rights you possess, and the extent of police powers
is crucial. Know what is happening to you. Once you know your rights, you can identify when they are
violated. Second is activism; to protest for change, for justice, such as the current Black Lives Movement.
However, above all is understanding white privilege and supremacy. For white people, it becomes hard to help having
not understood and accepted that they experience white privilege. Use your privilege to make a difference. Do not feel
so embarrassed of experiencing privilege that you fall silent. You did not choose to be white as much as George Floyd
did not choose to be black. Additionally, note that even if you are a person of colour, if you are not the group being
oppressed and targeted, you experience privilege and you can use it. ‘I do not see race’ (the widely held belief that skin
colour does not play a role in interpersonal interactions and institutional policies/practices 96 ) is not the approach, it is
ignorance of the long history of racism. Findings overwhelmingly suggest that when white people do not pay attention
92
ibid
93
<https://cbsloc.al/2Bsih5y> accessed 3 June 2020.
94
<https://mappingpoliceviolence.org/> accessed 30 May 2020.
95
<https://www.sentencingproject.org/publications/un-report-on-racial-disparities/> accessed 3 June 2020.
96
H. A. Neville, M. E. Gallardo and D. W. Sue, ‘The Myth of Racial Color Blindness: Manifestations, Dynamics, and Impact’ (2016) The American
Psychological Association
12

to race, there is often a negative effect on people of colour. 97 Another common statement is that ‘all lives matter’. The
Black Lives Matter is not to say that black lives are more important than others, it is to acknowledge that black lives
are undervalued, and this needs to come to an end. Kris Straub, a cartoonist, demonstrates this well. If a house was
burning down, you are going to focus on that house, you would not water every house on the street. In this case, the
black community lives in the burning house whereas everyone else lives more comfortably in the house that is not
burning down. 98
For people of colour, understanding white privilege is understanding that there are differences in treatment and that
they are wrong. While I have never experience racism to the degree of my black brothers and sisters, I can speak from a
place of some understanding. As an Indian-British woman, all my life, I had experienced differences and not
understood why, believing that I simply lacked the qualities of a likeable person such as attractiveness or intelligence.
Eventually, I began to spot the difference in treatment I would receive compared to my white peers. I was often told
that this was not the case, that I am imagining things and that I am not treated differently. As a result, I began to
accept it, that I was just insecure. Now it is clear to me, it is not something to take, it is something to fight against.
Recognising inequalities is harder than it seems, many people of colour argue that they do not feel like they are
disadvantaged, I was one of them, especially concerning the job market but you don’t realise until you look at the
statistics.
Understanding White Privilege
White privilege is a concept many white people have difficulty understanding and identifying. Robert Amico puts it
well in his book Exploring White Privilege, reading the experiences of Peggy McIntosh, a feminist and anti-racism
activist. McIntosh came to realise her advantages when first understanding her disadvantages as a woman and observing
men’s inability or unwillingness to recognise their advantages. Amico understood this and acknowledged his prior
belief that the idea of men being privileged came from bitter women who couldn’t make the grade.
McIntosh gives the following explanation of white privilege:
I have come to see white privilege as an invisible package of unearned assert, which I can count on
cashing in each day, but about which I was ‘meant’ to remain oblivious. White privilege is like an
invisible weightless backpack of special provisions, maps, passports, codebooks, visas, clothes, tools and
blank checks. 99
She then gives examples of privileges she experiences: ‘I can turn on the television or open to the front page of the
paper and see people of my race widely represented… I can go into a music shop and count on finding the music of my
race represented, into a supermarket and find the staple foods which fit with my cultural traditions, into a hairdresser’s
shop and find someone who can cut my hair…. I can choose public accommodation without fearing that people of my
race cannot get in or will be mistreated in the places I have chosen… I can choose blemish cover or bandages in “flesh”
colour and have them more or less match my skin.’ 100
These are small everyday examples which expose just how much racism influences every part of life. Many other
modern-day cases were seen earlier in this essay when looking at the role of the media in institutional racism. The key
is to use white privilege to help. To illustrate the usefulness of white privilege, Heather M Rasinski and Alexander M
97
ibid
98
German Lopez, ‘Next time someone tells you “all lives matter” show them this cartoon’ (11 July 2016, Vox)
<https://www.vox.com/2015/9/4/9258133/white-lives-matter> accessed 2 June 2020.
99
Peggy McIntosh, ‘White Privilege: Unpacking the Invisible Knapsack’ (1988)
100
ibid
13

Czopp found that white observers were more persuaded by white confronters than black confronters, seeing black
people as rude. 101 Similarly, Kevin Munger showed the effect on white privilege on the social platform, Twitter. Using
bots with either black or white identities (only variable to have changed was race – same followers), he tweeted at
harassers using the n-word, “Hey man, just remember that there are real people who are hurt when you harass them
with that kind of language.” Over seven days, there was a reduction of racist online harassment after the white bot
tweeted but little to no effect after the black bot tweeted. 102 These studies show how to use white privilege to help,
stand alongside the black community in any way you can.
Protesting for Justice
It was hard and will be hard. Countless people have
died or have been injured irrespective of the approach,
violent or non-violent, allies and African Americans
alike. Even with most forms of protest being nonviolent
(sit-ins, marches, speeches, boycotts), police
overreact, usually with excessive force. But this remains
true, protesting is
successful, as
displayed with
the Civil Rights
Movement.
Figure 9: Freedom Rider Jim Zwerg waits for
transportation to a hospital (segregation laws
prohibit Black taxi drivers from giving rides to
whites, and white cabbies refuse to transport
Freedom Riders of any race.
Concerning the
rioting occurring
in May/June
2020, while it is
were killed in Yemen, 3500 in Syria and 100 in Bahrain.
Disorganisation is also an issue, violent protest groups often lose
control of its followers leading to the excessive destruction of
property, fires and deaths. Remaining peaceful effectively singles
out racist biases of the police force as no other reason for brute
force would be left. Psychologist David Halpern stresses that ‘the
Figure 3:Bertha Gilbert, 22, is led away by police after she tried to enter a segregated
lunch counter in Nashville, May 6, 1964
natural and human to want to turn to violence, we should refrain and avoid
giving reasons for the use
of force. It only reinforces
the racist ideas about the
black community that
many still seem to hold.
More importantly, violent
protesting is more likely to
result in deaths. As an
example, 250 protesters
Figure 10: SNCC Field Secretaries Avery Williams and Chico Neblett
arrested for trying to bring water to voter applicants waiting for hours in
line at the courthouse.
protests that grow to scale are able to recruit people. And if you get that wrong, you won’t get your early majority
101
Heather M Rasinski and Alexander M Czopp, ‘The Effect of Target Status on Witnesses’ Reactions to Confrontations of Bias’ (2010) 32 Basic
and Applied Social Psychology 8.
102
Kevin Munger, ‘Tweetment Effects on the Tweeted: Experimentally Reducing Racist Harassment’ (2017) 39 Political Behaviour 629.
14

assembled’ 103 He states that teenagers are the key, ‘they are able to recruit and persuade the more reluctant older
folks’. 104 However, naturally, the frustration increases when peaceful protests are met with violence. Riots and looting,
while a problem and while we can be sad about that, is not a problem that we should prioritise. Shops can be rebuilt.
Again, as I have stated before, this is not about one incident, this goes back to the first slaves.
Regardless, an uprising is inevitable and needed, being the only thing that can make an impact on inequalities as we
have seen though all of human history. Choosing an approach is difficult and something that must be left to the black
community. However, violent or non-violent, what is needed is unity of the black community and allies and resilience.
Outside of protests, there should be constant advocation for equal rights, the conversation should never stop. Be on
the right side of history.
103
Amy Barrett, ‘Peaceful protests: Are non-violent demonstrations an effective way to achieve change?’ (2 June 2020, Science)
<https://www.sciencefocus.com/science/peaceful-protests-are-non-violent-demonstrations-an-effective-way-to-achieve-change/> accessed 2 June
2020.
104
ibid
15