One of the greatest challenges facing U.S.-based human rights activists today is proving the claims of Christian asylum-seekers claiming religious persecution in the Middle East. Native Christians have been terrorized in Egypt, jailed in Pakistan, and enslaved for their beliefs in the Sudan, yet they have received relatively little sympathy from U.S. courts hearing their asylum claims. There are exceptions. Christians from notoriously anti-Western countries such as Iran are among the best candidates for asylum, but their co-religionists from other more friendly states like Pakistan and Jordan have more difficulty proving their claims. In the case of Egypt's Coptic Christians, for example, courts have dismissed human rights activists' claims of persecution as mere discrimination.1
Christian groups have charged the Immigration and Naturalization Service (INS) with imposing impossible tests for asylum (such as demanding that applicants explain complex theological concepts).2 Richard Czik of the National Council of Evangelicals has argued that the appeals of Evangelicals are routinely denied by a bureaucracy insensitive to religion.3 Other advocates note that immigration judges frequently are unwilling to acknowledge that Christians face imprisonment or death in several countries. The INS denies these charges.4 And indeed, since the enactment of the International Religious Freedom Act of 1998, its asylum officers have shown a greater sensitivity to the problem of religious persecution, while the agency as a whole pursues its undeniable obligation to detect fraudulent asylum applicants and deport them from the United States.5 (Nearly one third of asylum decisions are made by INS officers, leaving two thirds to be decided by the courts. For some INS country statistics for 1998, the latest year for which complete statistics exist, see the table on page xx.)
But, despite some recent improvements, the situation still remains critical for many Middle Eastern Christians seeking asylum in the United States. I have represented clients at several asylum interviews where applicants whom I believed to be sincere converts were grilled over theological concepts which had questionable bearing on their actual beliefs. Further, having argued many asylum cases in court on behalf of Christians facing persecution in Muslim countries, I can state that there has been at times a lack of familiarity with the conditions faced by Christians in Muslim countries on the part of the private bar, INS prosecutors, and the immigration judges of the Executive Office for Immigration Review (EOIR), the separate government agency that reviews such cases in administrative hearings. For some Christians, this creates a dangerous situation in which they can neither live in their home countries nor obtain refuge abroad.
The Problem in the Courts
Under U.S. law, an alien can be granted asylum if he or she is (1) physically present in the United States and (2) fears returning to his country of origin due to persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion. Limitations exist for aliens who have been determined to have been firmly resettled in a third country, those who have been determined to be aggravated felons, and those would-be applicants who have waited more than a year after entry to file for asylum.6 While some undeserving asylum-seekers probably do slip through the ranks of those who are actually granted asylum, proving an asylum case before either the Immigration Service or the Immigration Court is not easy. Immigration judges often require voluminous documentation establishing a claim along with affidavits or the testimony of witnesses.
Virtually all decisions are influenced by two State Department publications—the annual Country Reports on Human Rights Practices and the periodic Profile of Asylum Claims and Country Conditions.7 The latter reports are specifically intended to help adjudicators assess such matters as the accuracy of an asylum applicant's assertions, likely treatment in the event of the applicant's return, whether persons similarly situated are known to be persecuted, and whether grounds for denial are known to exist.
While some INS officers and immigration judges give the State Department publications only modest weight, many consider the profiles nearly as binding as a statute. Indeed the Board of Immigration Appeals in a 1997 decision has held that "the profile, in the absence of contradictory evidence is entitled to considerable deference," reaffirming previous decisions that the profiles are "the most appropriate and perhaps the best resource for information on political situations in foreign nations."8
The case of Farid Ghaly, an Egyptian Copt, is typical. Ghaly had applied for asylum in the mid-1980s, claiming that Christians were subjected to discrimination and even violence in Egypt due to their faith. At a 1987 merits hearing on his asylum case, an immigration judge admitted a March 1986 State Department report that concluded that Copts faced prejudice and occasional acts of individual discrimination from Egypt's Muslim majority, but denied that these acts were systematic or officially inspired. Both the Board of Immigration Appeals and the (generally liberal) Ninth Circuit Court of Appeals based in San Francisco found that while Copts are subject to discrimination in Egypt, this was insufficient as a basis to grant asylum. Both upheld the judge's decision denying Ghaly's asylum.9 Other decisions similar to this one have been issued in cases deemed not legally presidential, meaning that the decisions may not be cited by the Courts of Appeal.10 In an asylum case argued by this author, an immigration judge in reviewing the asylum claim of a Pakistani Christian relied heavily on the State Department profile, disregarding extensive information from other sources including numerous articles on violence against Christians in Pakistan, culled from a variety of sources. For many Christians, then, the State Department profiles often mean the difference between the granting or denial of an asylum application.
Christian groups argue that the State Department publications fail to address the general population's role in the persecution of religious minorities when a passive government does not take efforts to stop the problem. They also argue that the reports do not adequately distinguish among various Christian denominations, but instead (because problems faced by small Christian minorities are not well documented) generalize from the experiences of the dominant religious group which is often the one with the most freedom.11 From a completely different vantage point, the Lawyer's Committee for Human Rights has in the past found the profiles of little value because of "factual errors, misstatements, and tendentious reporting," and has urged the State Department to abolish them.12
While many other refugees have had the formidable support of such human rights groups as the American Civil Liberties Union (ACLU), El Rescate Legal Services (based in Los Angeles which provides legal aid to aliens), and Public Counsel, Christians from Muslim countries often face legal battle without the help of organized lobbies or interested media. The major human rights organizations in the United States have paid relatively little attention to the alarming situation of millions of Christians suffering indignities in the Muslim countries. They often leave out religion as an element of persecution from their reports. Amnesty International (AI) for example, is often willing to identify people as "ethnic," "political leaders," "intellectuals," or "secular intellectuals," but is much less frequent in identifying Christians in their reports.13 This trend appears to continue with some though not all of Amnesty's most recent reports. Indeed the organization's Middle East and North Africa- Highlights for 2000 (covering events from January to December 1999) does not mention the persecution of Christians in summaries of events in various countries.14
The Problem of Silence
This lack of interest by human rights monitors appears largely to be based on the secular orientation of many of those involved in news reporting from the Middle East and academic study of the region. Some Christian leaders believe the problem is exacerbated by a reflexive tendency to see Christians as persecutors rather than persecuted. According to Nina Shea, director of the Puebla Program division of Freedom House, a foundation dedicated to documenting human rights violations around the world, much of the news media is either unaware of the stories of Christian persecution or is unwilling to see "news value" in the stories, while their academic counterparts rarely discuss the problem in scholarly publications.15
Paul Marshall of Freedom House, who has studied the worldwide persecution of Christians, notes that there is a deafening silence concerning the persecution of Christians when one turns to secular news outlets, academics, policy analysts and political activists. In Marshall's view, secularists tend to believe that Enlightenment culture constitutes the common opinion of mankind,16 and that survey research shows that reporters, columnists, and editors are far more secular than the majority of the U.S. population. While 60 percent of Americans can be found in a place of worship at least once a month, the corresponding number for members of the media is estimated at 10 percent. According to Marshall, such secular orientations generally lead to reporters with either little knowledge of religious issues or little interest in verifying religious situations.17
Bat Ye'or, an author of Egyptian origins living in Switzerland, who has studied the position of Jews and Christians under Islam (what she calls dhimmitude), offers a different explanation. She cites the doctrine of an Islamic-Christian symbiosis developed at the end of the nineteenth century by Eastern Christians as a shield against the terror and slavery permeating the Middle East. According to her, any mention of jihad or the persecution of Christians by Muslims became a taboo subject; one could not simultaneously proclaim the existence of an ongoing Islamic-Christian symbiosis and denounce persecution. The silence that developed out of this symbiosis continues until today.18
The real or perceived associations of some Christian groups with the anti-immigration lobby may also explain why the establishment human rights organizations lack interest in the persecution of Christians. The anti-immigration lobby19 has criticized many human rights activists for pursuing a leftist agenda.20 In some contexts, the charges may be true, but it is also the case that anti-immigration groups have wrongly accused mainstream liberals of supporting a radical agenda. This political bickering ends up alienating secular and liberal activists who may incorrectly perceive the campaign to protect persecuted Christians as an issue of concern only to the Christian right, and not as an issue of importance to all those concerned with human rights.
The net result of all this is clear: Christians from Muslim countries are falling through the cracks.
American responses to the crisis facing Middle Eastern Christians aim to include two elements: easing their plight in their home countries and ensuring proper consideration of their asylum claims. The history of this response can be seen in terms of a handful of proposals, starting in 1996.
National Association of Evangelicals. The first in-depth proposal on the situation was by Michael Horowitz, a senior fellow at the Indianapolis-based Hudson Institute's Washington, D.C. office, which was adopted by the National Association of Evangelicals. The association offered a comprehensive set of proposals that call for:
Public acknowledgment of today's widespread and mounting anti-Christian persecution and the adoption of policies condemning religious persecution whether it results from official policy or other sources. This includes instructing U.S. ambassadors to meet regularly with church leaders and Christian dissidents in countries where persecution occurs; and that the president deliver a major policy address on this subject as a way to initiate a public commitment to combat anti-Christian persecution.These define, indeed, the steps that can easily be implemented and which would be widely supported by the American public. Unlike many other foreign policy issues, the plight of oppressed Christians is one that has strong appeal to a large segment of the American public. Indeed, the movement to aid persecuted Christians has drawn a wide range of Americans who have never before paid much attention to foreign affairs or human rights. They are beginning to exert an influence on foreign affairs by writing letters, donating funds, and traveling to refugee camps in Africa and Asia to deliver Bibles and gather testimony on the suffering of Christians.22
Issuance by the State Department's Human Rights Bureau and related government agencies of more carefully researched, more fully documented, and less politically edited reports of the facts and circumstances of anti-Christian and other religious persecution. The State Department is called on to distinguish between the treatment of Christian groups in a given country; and that reports issued by the Bureau of Democracy, Human Rights and Labor in the State Department make explicit their findings when anti-Christian or other religious persecution occurs, thus eliminating the "option of silence."
Cessation of the indifferent and occasionally hostile manner in which the Immigration and Naturalization Service often treats the petitions of escapees from anti-Christian persecution.
Termination of non-humanitarian foreign assistance to countries that fail to take vigorous action to end anti-Christian or other religious persecution, with resumption of assistance only after the president issues a written finding that the country in question has taken all reasonable steps to end such persecution, making sure it will not be resumed.21
The Evangelicals' recommendations for U.S. trade officials and the INS were somewhat more controversial. It called on the former vigorously to object to religious persecution and link negotiations with the need for constructive change. This demand prompted considerable opposition from others who thought that bill could be harmful to American business interests. Assistant Secretary of State John Shattuck has argued that the bill would pose the risk of challenge as inconsistent with international legal obligations including the World Trade Organization agreement and other trade law.23 Dan Griswold, director of trade and immigration studies at the Cato Institute, holds that sanctions stifle private trade and investment and tend to reduce the opportunity of the mass of people to improve their conditions.
As for the INS, the Evangelicals urged that the attorney general issue a bulletin to INS officers that acknowledged mounting anti-Christian persecution and directed officers to process the claims of escapees from such persecution with priority and diligence. It also recommended the establishment of INS listening posts in those countries from which refugees from anti-Christian persecution often flee.23 These instructions are problematic because they legally mandate the processing of all Christians—even those with relatively minor claims—ahead of other applicants, even those who were jailed or tortured, so long as this was for non-religious reasons. INS listening posts in the countries of persecution would require creating from scratch a corps of officials with the education and linguistic skills to perform such functions; this, too, seems problematic. How such posts would be able to function in the countries of persecution raises other problems.
The Freedom from Religious Persecution Act. Another proposal, which held considerable sway with many politicians, was a bill put forth by senators Frank Wolf (Republican of Virginia) and Arlen Specter (Republican of Pennsylvania).24 The Wolf-Specter bill would have created an office to monitor religious persecution in the White House, which would have certified religions whose members are persecuted. Members of certified religions would not, as asylum applicants, have needed to prove persecution, but merely to have credibly claimed membership in the said religion. Officials seeking to deny such a person admission would have been required to furnish proof that he was not a member of the religion.
The bill offered some tangible solutions to the crisis, including a bar to all non-humanitarian aid to sanctioned countries, a requirement that the U.S. vote against international loans to sanctioned countries, and the application of the same sanctions applied to apartheid South Africa to the Sudan (where Christians have been sold into slavery).
The act provoked protest from several quarters. Conservatives like William Buckley called the bill both "honorable in its province and blessed in its purpose" but labeled it unworkable because it would invite chaos.25 Muslim groups claimed it ignored the persecution of Muslims,26 while Jewish groups were apparently reluctant to support it due to its embrace by the religious right.27
International Religious Freedom Act. The considerable opposition to the Wolf-Spector bill prompted the sponsorship of another bill, H.R. 2431, which on October 27, 1998, was signed into law as the International Religious Freedom Act of 1998 by President Clinton.28 Though softer than the previous two proposals, it was hailed as a potentially powerful tool in stopping the rising level of religious persecution around the world.
The law created fact-finding agencies in Congress, the White House, and the State Department to monitor and report on religious freedom around the world. It created a bipartisan Commission on International Religious Freedom29 and required both the State Department and the commission to issue annual reports on international religious freedom and obligates the president to choose a response to an offending country from among fifteen options ranging from a private diplomatic rebuke to full economic sanctions.30
What impact did these steps have? Nina Shea has noted that the law has made a small difference, as officials no longer tell her that the principle of separation of church and state prevents them from dealing with issues of religious persecution.31 Others express disappointment. After the State Department's negative assessment of the situation in a number of countries (including Iran, Iraq, and Sudan), many advocates of religious freedom have expressed concern that there was no practical effect on those found to be persecutors. In a September 2000 hearing on the State Department's second annual report, Representative Christopher H. Smith (Republican of New Jersey), noted that the report "may not have any practical effect on U.S. policy," while others questioned whether the process would be more than just an exercise if the United States did not take a stronger response to those found guilty of persecution. Indeed while the 1999 report offered considerable discussion about steps which were being implemented to alleviate religious persecution, the 2000 report evidences a very cautious approach to the problem. Robert A. Seiple, the special international religious freedom advisor to the president and secretary of state, was described as seeking "to promote, not punish." 32 The reports on the situation in individual countries seemed at least as attuned to foreign policy objectives as to reporting on religious persecution.
Further Initiatives. Additional steps can be taken by the U.S. government to reduce the persecution of Christians abroad.
* Cultivate moderate Muslim leaders calling for tolerance of Christians and perhaps include them in a joint committee of Christians and Muslim clerics.
* Have American diplomats and trade officials stress in meetings with Muslim officials and business leaders that the United States, as a predominantly Christian country, has a special interest in protecting Christian minorities.
* Separate the tasks of limiting immigration and the monitoring of human rights conditions abroad so they are undertaken by distinct bodies. Such a division would eliminate charges that the State Department does not adequately consider persecution in a given country and allows the fact finder in such cases to make the decision within the judicial system.
* Have the INS use academic consultants and psychiatrists in determining that an applicant has been persecuted.
Alternative Sources for Corroborating Claims
Persecuted Christians have quite a bit of material at their disposal that they can use to win relief in the immigration court. Conversely, the U.S. courts must make greater use of existing organizations and their resources.
The established human rights organizations publish reports on specific issues that are far more effective than their general summaries. For example, Amnesty International's booklet on Pakistan, Time to Take Human Rights Seriously, includes an entire chapter on the problem of religious minorities in the country and explains how, under section 295-C of the Pakistan penal code, anyone defiling the name of the Prophet Muhammad is punished with life imprisonment or death. This and other sections of the penal code have been used to intimidate, harass, and punish hundreds of people solely for having exercised their right to freedom of religion. While some of the victims have been Muslims, the primary targets have been Christians and Ahmadis. 33
In addition, organizations specifically dealing with the problems of Christians in the Middle East produce excellent materials. The American Coptic Association, Christians of Egypt, based in New Jersey and southern California and largely composed of lay individuals desperately concerned with the fate of their co-religionists, is among the most vociferous advocates on behalf of persecuted Christians. The group compiles its reports from news articles and the reports of visitors to Egypt. It is often the only group to publicize certain crimes against Egypt's Christians.
Iranian Christians International (ICI), based in Colorado Springs, since 1980 has been one of the best sources for learning about the problems of Christians in the Middle East. It monitors the situation of Christians in Iran and other Muslim countries and by its account has assisted nearly 500 individuals—mostly converts from Islam—in their application for U.S. asylum. ICI claims that 95 percent of the applicants it has prepared were accepted into the United States.34 ICI has also published a formidable report, The Continued Persecution of Minorities in the Islamic Republic of Iran, based on information from refugees and contacts in Iran, that tells about the persecution of Evangelical Christians, Islamic laws regarding the treatment of apostates, and the persecution of Christians who returned to Iran after failing to win asylum in other countries.35 ICI's founder and director, Ebrahim Ghaffari, has prepared an extensive affidavit regarding the status of Muslim converts to Christianity in the Islamic Republic of Iran, in which he has synthesized the various sources including the State Department reports and the laws of Iran. Of particular importance is his analysis of the various fatwas of Islamic jurists, which discuss the basis on which some Christians have been sentenced to execution for apostasy.36
The Zwemer Institute for Muslim Studies (recently relocated from Pasadena, California, to Fort Wayne, Indiana), is another source of information. In particular, David Bentley, a minister and senior researcher with the Institute, has noted the inherent contradiction in the 1981 Universal Islamic Human Rights declaration which guarantees the right to freedom of belief but then goes on:37
Every person has the right to express his thoughts and beliefs so long as he remains within the limits prescribed by law. No one, however, is entitled to disseminate falsehood or to circulate reports which may outrage public decency, or to indulge in slander, innuendo, or to cast defamatory aspersions on other persons.Bentley understands this to mean that any Muslim who chooses to leave Islam can be accused of slander; and Evangelism falls under the rubric of slander or corrupting societies. He argues that Christian Evangelists must convince the authorities in Muslim countries that Christians favor a state which upholds human rights for all its citizens. This concept of equal rights for all religions may present a problem for Christians seeking to evangelize in countries where all missionary efforts are deemed offensive. Yet as Paul Marshall implies, attempts to spread beliefs which involve coercion or manipulation could be regulated by criminal law rather than with blanket restrictions on freedom of religion.38
Personal documentation can also be extremely useful in corroborating claims. This is often difficult to obtain, for many would-be asylees and refugees flee their home countries with just the shirts on their backs. Others intentionally leave supporting documentation behind to avoid arrest by border guards. However, various documents such as arrest records often do exist; for example, they might be found in the possession of an asylum applicant's family. Documentation which might never strike an applicant as pertinent can also often be easily obtained. In one case, argued in Immigration Court by the author, a Copt who had applied for asylum from Egypt claimed that his business of manufacturing Christian religious pennants was disrupted by fundamentalist Muslims. An initial review of his case made it appear that he had little documentation to corroborate this claim; a more intensive investigation turned up some of his merchandise, including numerous pennants depicting Coptic religious figures. This made it possible for him in court to prove that his problems were linked to his Coptic faith. In another case, an applicant showed me newspaper articles about his priest who was assassinated in Egypt but seemed unable to prove that the murdered cleric was actually his priest. Yet the proof he needed was in his possession: his wedding photos showed the priest officiating and their marriage certificate bore his name. Affidavits can be obtained from these who know an applicant to establish Christian identity, or from an American clergymen to attest that this person possesses knowledge of the particular community in his home country and is seriously dedicated to his faith.
The issue of Christian persecution has moved to the top of the human rights agenda in the United States thanks to an alliance that brings together Christian activists of an Evangelical and conservative orientation with Jewish intellectuals who see parallels here with the historic persecution of Jews. Michael Horowitz, whose family survived the Holocaust, notes that Christians "are the scapegoats of choice" of tyrannical regimes. He adds, dramatically: "I would be a bar of soap, a lampshade, were it not for the rooted faith of church-going Americans."39 A.M. Rosenthal, The New York Times-based columnist shocked into action by Horowitz, has written extensively on the issue, citing the lack of action taken to stop the persecution.40
The movement has generated the impetus for Congress to pass the International Religious Freedom Act; on the grassroots level, a new kind of solidarity movement has grown among American Christians who focus on what they call "persecuted church," or fellow Christians who are the targets of abuse solely due to their faith. Yet Christian groups are not united on what tactics to use. Mainline churches take a much more conciliatory approach than Evangelical groups. Further, some Christians inside Middle Eastern countries are wary of U.S. efforts to publicly raise the problem.41
American Muslim leaders and some Christian missionaries in Islamic countries have expressed concern that the Christian persecution movement could cultivate anti-Muslim sentiments;42 after all, stories of persecution at the hands of Muslims can inspire powerful emotions. Typical is an advertisement in The Washington Times published by the International Coptic Federation in the form of an open letter to President Mubarak stating in bold headlines: "Stop the Kidnapping, Rape, and Forced-Conversion of Young Coptic Christian Girls." .43 Are Christians in fact creating an enemy image of the Muslims and aggravating the problem? Certainly, an image of Muslims all holding fanatical anti-Christian views does not help achieve the ultimate goal of reducing persecution; one of the most important strategies towards resolving the entire issue is to involve moderate Muslims in interfaith dialogue. Yet the public must be informed of the outrages perpetrated upon Christians, both to inspire public action and to help potential asylees to document their problems.
If the situation of Middle Eastern Christians remains as serious as it is now, the courts will see even more cases brought on behalf of Christians who have been persecuted in the Islamic countries. For those of us dealing with facts on the ground, proving the claims of such persecuted minorities will then remain the foremost concern.
Louis Gordon has argued many asylum cases before the immigration courts involving Middle Eastern applicants facing religious persecution. He is at work on a book on the current controversy over immigration to the United States.1 See Ghaly v. INS, 58 F.3d 142 (9th Cir. 1995). The Eighth Circuit affirmed a judge's reliance on a State Department decision in Yacoub v. INS, 999 F.2d 1296 (8th Cir. 1993), asserting there was no systematic official discrimination in Egypt and that the situation had improved since outbreaks of religious violence in the early 1980s. In denying an asylum case, the Ninth Circuit in El Nager v. INS, 93 F.2d 784 (9th Cir. 1991), cited a Bureau of Human Rights and Humanitarian Affairs report which concluded that El Nager as a convert was not subject to "government inspired or tolerated" persecution, and that "Full judicial and administrative remedies exist in Egypt and the government goes to considerable efforts to answer that violence or the threat of violence against Christians—converts or otherwise—does not occur." The Board of Immigration Appeals has defined persecution as harm or suffering inflicted upon an individual in order to punish him or her for possessing a belief or characteristic the entity inflicting the suffering or harm intends to overcome. Matter of Acosta, 19 I & N Dec. 211 (BIA 1985). Though discrimination is not normally persecution, discriminatory practices and experiences can accumulate in intensity so that they rise to the level of persecution. UNHCR Handbook on Procedures and Criteria for Determining Refugee Status, (CD Rom West Group 2000), paragraph 54-55; see INS Basic Law Manual (BLM) (CD Rom West Group 2000), pp. 23-24.
2 Los Angeles Times, July 23, 1997.
3 Paul Marshall, Their Blood Cries Out: The Worldwide Tragedy of Modern Christians Who Are Dying for Their Faith (Dallas: Word Publishing, 1997), p. 227.
4 Los Angeles Times, July 23, 1997.
5 In October 2000, the INS received 3,889 asylum applications, approved 1,669, denied 707, otherwise closed 2,184 cases, referred 1,031 cases to the Immigration Court, and claimed a total backlog of 327,307 cases pending. Immigration & Naturalization Service website, http://www.ins.usdoj.gov/graphics/aboutins/statistics/msrsep00/asylum.htm.
6 Immigration and Nationality Act, section 101(a)(42)(A); section 208.
7 Egypt: Profile of Asylum Claims and Country Conditions (Washington, D.C.: U.S. Department of State, Bureau of Democracy, Human Rights and Labor, June 1996), p. 1.
8 In Re T-M-B, this is the official published citation there is no spelled out version] an administrative decision by the Board of Immigration Appeals, Int. Dec. #3307 (BIA 1997), p. 6.
9 Ghaly v. INS.
10 See Mikhael v. INS, 50 F. 3d 299 (9th Cir., 1995); Rouman v. INS, 983 F. 2d 1077 (9th Cir., 1993); Sidhum v. INS, 165 F. 3d 917 ((9th Cir., 1998); Magharyos v. INS, 1999 WL 824622 (9th Cir., 1999).
11 Nina Shea, In the Lion's Den: A Shocking Account of Persecution and Martyrdom of Christians Today and How We Should Respond (Nashville: Broadman & Holman, 1997), p. 20; Marshall, Their Blood Cries Out, pp. 206-207. Shea contends for example that the country report on Ethiopia ignores the plight of the minority Evangelical Protestants, limiting its religious discussion to a riot within a mosque that was the result of an inter-Muslim dispute.
12 Lawyers Committee for Human Rights Critique: Review of the U.S. Department of State's Country Reports on Human Rights Practices for 1994 (New York: Lawyer's Committee for Human Rights, 1995), pp. v-vi.
13 Marshall, Their Blood Cries Out, p. 205.
14 Middle East and North Africa: Highlights of Amnesty International Report 2000, covering events from Jan. to Dec. 1999, at http://www.web.amnesty.org/web/ar2000web.nsf/reg/ 27f43cfc8a8247df802568f2005a7622.
15 Shea, In the Lion's Den, pp. 17-18.
16 Marshall, Their Blood Cries Out, p.183.
17 Ibid., p 184.
18 Testimony for the U.S. Senate Foreign Relations subcommittee hearing on religious persecution in the Middle East, May 1, 1997, cited in "Cocoon of Lies," Middle East Digest, Aug. 1997, at http:\\www.cdn-friends-icej.ca/medigest/aug97/cocoon.html.
19 Including such organizations as the American Immigration Control Foundation and the Federation for American Immigration Reform (Fair).
20 See for example, William Hawkins, Importing Revolution: Open Borders and the Radical Agenda (Monterey, Va.: American Immigration Control Foundation, and Washington, D.C.: U.S. Business and Industrial Council Educational Foundation, 1994), pp. 59-99.
21 "Selections from the Statement of Conscience of the National Association of Evangelicals,"
Wash., D.C., Jan. 23, 1996, as cited in Marshall, Their Blood Cries Out, pp. 241-243.
22 The New York Times, Nov. 9, 2000.
23 Statement before House International Relations Committee, Sept. 9, 1997, http://usaengage.org/legislative/Shattuck.html.
24 Daniel T. Griswold, "Christian Groups Should Be Wary of Economic Sanctions," Cato Just In, Oct. 3, 1997, at http://Cato.org/daily/10-03-97.html.
23 Marshall, Their Blood Cries Out, p. 243.
24 HR. 1685, Freedom from Religious Persecution Act of 1997, at htttp://usembassy-israel.org.il/publish/press/congress/archive/1997/august/uc20821.htm.
25 William F. Buckley, Jr., "On the Right, Religious Persecution: The Protesters," The National Review, Nov. 10, 1997, p. 66.
26 Pakistan Link, Sept.18, 1997, at http://www.pakistanlink.com.
27 The Forward, July 7, 1998.
28 International Religious Freedom Act of 1998, H.R. 2431 P.L. 105-292.
29 Currently chaired by Elliott Abrams; see the interview with him on pp. Xxxx.
30 U.S. Department of State Annual Report on International Religious Freedom for 1999, http:// www.state.gov/www/global/human_rights/irf/irf_rpt/1999.
31 Teresa Watanabe, "Tracking Religious Freedom," Los Angeles Times, Sept. 9, 2000.
32 2000 Annual Report on International Freedom, Introduction, Bureau of Democracy, Human Rights, and Labor, U.S. Department of State, September 5, 2000, p. 3, at http://www.state.gov/www/global/human_rights/irf/irf_rpt/
33 Pakistan: Time To Take Human Rights Seriously (New York: Amnesty International USA, June 1997), pp. 22-25.
34 The Continued Escalation of Persecution of Evangelical Christians in the Islamic Republic of Iran, Condensed Update (Boulder, Co.: Iranian Christians International, Feb. 1999), p. i.
35 The Continued Escalation of Persecution of Evangelical Christians, pp. 1-24.
36 Affidavit of Ebrahim Ghaffari regarding the Status of Muslim Converts to Christianity in the Islamic Republic of Iran, (Boulder, Co.: Iranian Christians International, Nov. 14, 1996), p. 2.
37 David Bentley, "Islam and Human Rights," International Journal of Frontier Missions, July-Sept. 1996, pp. 155-158.
38 Marshall, Their Blood Cries Out, p. 259.
39 Buckley, "On the Right; Religious Persecution," p. 66.
40 Buckley, "On the Right; Religious Persecution," p. 66; A.M. Rosenthal, "On My Mind: Persecuting Christians," The New York Times, Feb. 11, 1997.
41 Telephone interview with David Bentley, Oct. 31, 2000.
42 The New York Times, Nov. 9, 1998.
43 Buckley, "On the Right; Religious Persecution," p. 66; A.M. Rosenthal, "On My Mind: Persecuting Christians," The New York Times, Feb. 11, 1997.