2017] CRITICAL RACE THEORY AND PROPAGANDA 461
terrorism.
32
Although there, too, the attack was initially blamed on Islamic
terrorist groups.
33
For the most part, though, “terrorist” was not a word applied to the white
Christian responsible for the Quebec City attack.
34
Nor is he alone in
avoiding classification as a terrorist.
35
That list also includes white
Christians, often white supremacists, whose ideologies drove them to attack
women’s health clinics,
36
police officers,
37
Jewish community centers,
38
and
Sikh temples.
39
It includes the white Christian extremist whose slaughter of
http://www.washingtonpost.com/wp-dyn/content/article/2005/06/04/
AR2005060400147.html [https://perma.cc/7MRB-DPJ9] (“He was linked to . . . white
supremacist groups in Oklahoma and Missouri, and at gun shows he sold copies of ‘The Turner
Diaries,’ a racist novel written by the founder of a neo-Nazi organization.”); Brandon Harris,
Oklahoma City Exposes the Origins of Today’s White Nationalism, N
EW REPUBLIC (Feb. 7,
2017), https://newrepublic.com/article/140467/oklahoma-city-exposes-origins-todays-white-
nationalism [https://perma.cc/66NA-KPCV].
32. This attack—the worst domestic terror attack before 9/11—killed 168 people,
including nineteen children in the federal building’s day care. Oklahoma City Bombing,
E
NCYCLOPAEDIA BRITANNICA, https://www.britannica.com/event/Oklahoma-City-bombing
[https://perma.cc/F3BZ-U8KB] (last visited Oct. 16, 2017).
33. Id.; see also Ali, supra note 6, at 1041 (recounting the assumptions of media, FBI, and
politicians in the immediate aftermath of the Oklahoma bombing); Nagwa Ibrahim, The
Origins of Muslim Racialization in U.S. Law, 7 UCLA
J. ISLAMIC & NEAR E.L. 121, 139 (2009)
(same).
34. See, e.g., Paula Newton et al., Quebec Mosque Shooting: ‘Lone Wolf’ Kills 6, Officials
Say, CNN (Jan. 31, 2017), http://www.cnn.com/2017/01/30/americas/quebec-mosque-
shooting/index.html [https://perma.cc/C39T-FH6B]. But see Ian Austen & Craig S. Smith,
Quebec Mosque Attack Forces Canadians to Confront a Strain of Intolerance, N.Y.
TIMES
(Jan. 30, 2017), https://www.nytimes.com/2017/01/30/world/canada/quebec-mosque-
shooting.html [https://perma.cc/8RUA-ANC7] (reporting that Prime Minister Justin Trudeau
“called [the attack] an act of terrorism”).
35. Leonard Pitts, White-Extremist Terror Rare?: History Argues Otherwise, S
EATTLE
TIMES (Feb. 12, 2017), http://www.seattletimes.com/opinion/white-extremist-terror-rare-
history-agues-otherwise/ [https://perma.cc/V6B7-8FQD] (listing examples and concluding
“[w]hen white people do it, it is less likely to be perceived—or reported by news media—as
terrorism”).
36. Ben Mathis-Lilley, The Long List of Killings Committed by White Extremists Since
the Oklahoma City Bombing, S
LATE (Aug. 14, 2017, 3:15 PM), http://www.slate.com/blogs/
the_slatest/2015/06/18/white_extremist_murders_killed_at_least_60_in_u_s_since_1995.ht
ml?cq_ck=1486485587473 [https://perma.cc/NS8F-TADB] (noting that, in 2015, a white
Christian extremist claiming to do “God’s work” attacked a Planned Parenthood in Colorado
Springs, Colorado, killing three and wounding nine).
37. Review-Journal Staff, Shooters in Metro Ambush That Left Five Dead Spoke of White
Supremacy and a Desire to Kill Police, L
AS VEGAS REV.-J. (June 9, 2014, 11:03 PM),
https://www.reviewjournal.com/local/local-las-vegas/shooters-in-metro-ambush-that-left-
five-dead-spoke-of-white-supremacy-and-a-desire-to-kill-police/ [https://perma.cc/TAF9-
DAWL] (noting that, in 2014, a white supremacist antigovernment married couple in Las
Vegas, Nevada, killed two police officers who were eating lunch, leaving a swastika and a
note stating “[t]his is the start of the revolution”).
38. Mathis-Lilley, supra note 36 (noting that, in 2014, a virulent anti-Semite who believed
the Jews were trying to destroy the white race attacked a Jewish Community Center and a
Jewish retirement home in Overland Park, Kansas, killing three).
39. Terror from the Right, S.
POVERTY L. CTR. (Nov. 1, 2015), https://www.splcenter.org/
20100126/terror-right [https://perma.cc/J6V3-CVZB] (noting that, in 2012, a neo-Nazi white
supremacist shot up a Sikh temple in Oak Creek, Wisconsin, killing six people). In addition,
in 2015, a white man who praised Hitler and the Westboro Baptist Church shot up a movie
theatre in Lafayette, Louisiana, killing two and wounding nine. Id.