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Nakia D. Hansen, J.D.
Multiculturalism and The Human Rights Of Women:
International And Comparative Law Perspectives
Professor Susanna Mancini
Cardozo Law School
On March 6, 2014, members of the self-described feminist group FEMEN
demonstrated in NYC’s Times Square demanding sanctions and the removal of
Russian troops from the Crimean Peninsula.
The small group of women strode into
Times Square, removed their coats, and revealed bare breasts painted with the
words, “Fuck [Vladimir] Putin” while screaming the same as a means of protesting
Russia's occupation in Ukraine. While this may have been a novel sight for the many
tourists that frequent the popular NYC destination, FEMEN’s tactics are nothing
new. The group’s brand of shock activism has spread from the Ukraine to China
its debatable whether FEMEN’s actions are in service of or contradictory to the
causes it purports to champion.
Beyond the debate of whether topless activism is productive or not, FEMEN
has got bigger problems that call into question the group’s feminist bona fides. In its
zeal to garner media attention for the sex trafficking and economic injustices faced
by women in Eastern European countries like Ukraine, FEMEN has been criticized
for espousing a racist, colonialist/imperialist point of view that silences women of
color, religious women, and anyone else that does not conform to its narrowly
construed view of what a “free woman” looks like.
In this paper, I will examine one of FEMEN’s most visible protests and discuss
the need for feminists to approach theory and praxis through an intersectional lens.
First, I will introduce FEMEN and the criticism that the group is colonialist, white
supremacist, and imperialist. Next, I will discuss the Topless Jihad Day and
Sunderland, M., FEMEN Brings Ukrainian Politics (and Boobs) to Times Square,
VICE.COM, March 7, 2014: http://bit.ly/1n7UBlg.
Vergnaud, L., Femen influence reaches restless China, BLOUINNEWS.COM, April 21,
subsequent responses from Muslim women followed by a look at similarly
alienating movements perpetrated by mainstream white feminists that excluded
women of color and the backlash that ensued. Finally, I will discuss the theory of
intersectionality and how FEMEN is doing it wrong, ultimately making the case that
feminism will fail to grow and achieve its goals if it does not proceed with an
What is FEMEN?
FEMEN is a feminist protest group founded in Ukraine in 2008. According to
the group’s website, “FEMEN is an international women’s movement of brave
topless female activists […] ready to implement the humanitarian tasks of any
degree of complexity and level of provocation. FEMEN is the special force of
feminism, its spearhead militant unit, modern incarnation of fearless and free
The group first captured international headlines in 2011 when, in
response to a radio show promising a “Ukrainian bride of his choice” to a contest
the nine founding members of FEMEN assembled in Kiev’s Independence
Square wearing wedding dresses and the flowered headdresses of traditional,
Ukrainian peasant brides. The women then proceeded to rip off the dresses,
revealing slogans written on their breasts.
Photographers captured the spectacle, resulting in FEMEN’s first
internationally recognized protest
. The subsequent international media attention is
IOLNews. Ukraine is not a brothel – Femen activists. INDEPENDENT ONLINE. 2011:
Miller, A., FEMEN’s ‘Topless Jihad’, THE NATION, July 1, 2013:
directly related to the group’s direct and somewhat extreme methods of action, a
reality that only fuels FEMEN’s dedication to such tactics. These topless
demonstrations and protests, or “Sextremism” as coined by FEMEN, “is female
sexuality rebelling against patriarchy and embodied in the extremal political direct
action events. […]Unsanctioned format of the sextremism events represents the
historical right of the woman to make her protest anywhere at any time and not to
concert her action with the patriarchal law-enforcing structures.”
FEMEN soon expanded its political platform beyond sex tourism in the
Ukraine to encompass their goal of “complete victory over patriarchy,”
based on the group’s objectives, is achieved through the “subversive trolling” of
dictatorships, the sex industry, and religion, “the fundamental institutes of
This broader outlook on feminism can be attributed to FEMEN’s de
facto spokesperson and most visible leader, Inna Shevchenko. Shevchenko rose to
prominence within the group in August 2012 when she cut down a 13ft cross
overlooking Kiev’s Independence Square with a chainsaw while baring her naked
breasts with the words “Free Riot” drawn across her chest
– all in protest over the
convictions of anti-Putin Russian rock group Pussy Riot. Following a criminal
investigation, Shevchenko was forced to flee from Ukraine to France where she was
granted asylum and founded a FEMEN training center in Paris.
Femen, supra note 3.
Polityuk, P., Ukraine activist cuts down cross in Russian female punk rock band
protest. REUTERS. August 17, 2012: http://reut.rs/1iIhN4m.
France24. France grants asylum to Ukrainian Femen activist. FRANCE24, July 8,
Although FEMEN makes it seem as though the group invented the idea of
female nudity as a form of protest (“Sextremism is a fundamentally new form of
women’s feminist actionism developed by FEMEN.”
), exposing the female body as
an act of empowerment has been employed throughout history and across
continents, from Nigerian women’s nude protests in 1929 to the bra-burnings of the
Sexual Revolution of the 1960’s and ‘70‘s. Thus, while FEMEN’s use of the female
body as a source of empowerment and locus of activism is not original, it is valid.
Therefore, my critique is not of the use of nudity alone but they way in which
FEMEN’s message is used in a manner that is counterproductive to feminism and
instead silences the voices of women that do not fit FEMEN’s ideal.
International Topless Jihad Day
In March 2013, Tunisian student-activist and FEMEN aspirant, Amina Tyler,
sparked controversy by posting pictures of herself online with the words "Fuck Your
Morals" and "My Body Belongs To Me, And Is Not The Source Of Anyone’s Honor,"
painted across her bare chest. Reportedly, the head of Tunisia's "Commission for the
Promotion of Virtue and Prevention of Vice," called for Tyler to be lashed and stoned
for her obscene actions in order to isolate the incident and prevent other women
from getting “ideas.”
Tyler’s Facebook page was hacked, communication ceased
and she was unreachable, prompting fear and worry for her safety.
reports, “[Amina’s] family kidnapped her, beat her, and held her in captivity for
Femen, supra note 3.
Salek, C., Amina Tyler: Tunisian Woman Receiving Death Threats For Trying to Start
Feminist Group. POLICYMIC. March 23, 2013: http://bit.ly/1n36WaC.
Tayler, J., Topless Jihad: Why Femen is Right. THE ATLANTIC. May 1, 2013:
three weeks, during which time they drugged her, subjected her to an amateur
virginity test, forced her to read the Quran, and took her on involuntary visits to
In response, FEMEN declared April 4, 2013 "International Topless Jihad Day"
and organized protests in several countries, its mission statement posted to the
group’s Facebook page: "This day will mark the beginning of a new, genuine Arab
Spring, after which true freedom, freedom without mullahs and caliphs, will come to
Tunisia! Long live the topless jihad against infidels! Our tits are deadlier than your
In support of the protests, women bared their breasts in true FEMEN
fashion, with various slogans scrawled on their chests and signs – “Free Amina,”
“Fuck Your Morals,” “Bare Breasts Against Islamism,” and “Topless Jihad.”
Curiously, a FEMEN demonstrator was photographed topless, on her knees, with
arms extended, simulating a prayer position while wearing a paper beard, penciled
in unibrow, and a towel on her head in mockery of a turban, the words “Viva Topless
Jihad” painted on her breasts.
This imagery, combined with orientalist language
and FEMEN’s anti-religion, anti-Muslim rhetoric was the final straw for many
women of color and Muslim women around the world.
Gordts, E., International Topless Jihad Day: FEMEN Activists Stage Protests Across
Europe. HUFFINGTON POST. April 4, 2013: http://huff.to/1mdXLCB.
Taylor, A., Femen Stages a ‘Topless Jihad’. THE ATLANTIC. April 4, 2013:
Gordts, supra note 15.
Muslim women reacted swiftly, launching the Facebook group “Muslim
Women Against FEMEN” on the same day as the Topless Jihad protests.
stated their position on Facebook as such:
This group is primarily for muslim women who want to expose
FEMEN for the Islamophobes/Imperialists that they are. We have had
enough of western feminists imposing their values on us. We are
taking a stand to make our voices heard and reclaim our agency.
Muslim women have had enough of this paternalistic and parasitic
relationship with SOME western feminists. The group is open to all,
muslim and non muslim, men and women.
This clear and unequivocal stance of Muslim women in direct response to FEMEN’s
actions (ostensibly on behalf of the very same women), led FEMEN’s Shevchenko to
reply, “[t]hey say they are against Femen, but we still say we are here for them, […]
They write on their posters that they don't need liberation but in their eyes it's
written 'help me.'"
Shevchenko’s message was received loud and clear: Muslim women don’t
know what’s good for them, reinforcing the ideology that “showing your breasts is
inherently liberating, and covering up is a necessary signifier of sexist oppression.”
FEMEN measures liberation by “the amount of flesh we're permitted to show.”
What Shevchenko fails to grasp is that you cannot demean a group of women who
do not believe the same as you and call it feminism. In doing so, FEMEN takes
Gordts, E., Muslim Women Against FEMEN. HUFFINGTON POST, April 6, 2013:
Badcock, E., That’s not what a feminist looks like. COUNTERFIRE. August 12, 2013:
Western standards and ideals and tells Muslim women that these are the right ideals
not whatever it is they mistakenly believe in.
In the view of FEMEN and much of Western society, these women are just too
sheltered and brainwashed to see the truth for themselves. “Thus, an otherwise
frankly racist discourse is camouﬂaged under the dialectic of the “insurmountability
of cultural differences,”
writes Professor Susanna Mancini in describing the “us vs.
them” stance of populist-feminist arguments. “Once Muslim culture is constructed as
incompatible with Western values, Muslims can only choose either to assimilate, by
renouncing to their (inferior) culture—including its visible symbols, such as the
Enter FEMEN to show oppressed women just how better they
could be by falling in line with a Western ideal of freedom. Constructing “culture” as
a barrier to women’s personal freedom reveals a liberal conception of the human
subject, where liberty – at a personal, individual level – is framed as especially
important and as the direct result of the elimination of cultural practices, without
taking into account the political, economic and social factors that are affected by
both local and global factors.
This approach recalls the “Savage-Victim-Savior” metaphor of feminism and
human rights. Law professor Makau Mutua writes about this Eurocentric approach
to human rights that pits “savages” against “victims” and “saviors”.
metaphor, the savage is “bad” culture in the form of a military state, cultural practice
Mancini, S., Patriarchy as the exclusive domain of the other: The veil controversy,
false projection and cultural racism. INTERNATIONAL JOURNAL OF
CONSTITUTIONAL LAW, (2012).
Mutua, M., Savages, Victims, and Saviors: The Metaphor of Human Rights. 42 HARV.
INT’L L. J. 201 (2001).
such as female genital mutilation, or a theocracy.
The victim is one “whose ‘dignity
and worth’ have been violated by the savage,” whereas the savior “protects,
vindicates, civilizes, restrains, and safeguards,” promising freedom based on
particular liberal values.
In this way, Muslim men (and Islam in general) are
painted as the savages, Muslim women (whose oppression is symbolized by the
veil), are the victims, and enlightened Western culture is, of course, the savior. This
approach ignores the realities of different cultures and places human rights activism
in a Western, Eurocentric framework that silences rather than elevates the voices of
the so-called victims.
If the true goal were to stand in solidarity with Amina Tyler and Muslim
women, a better approach by FEMEN would have been to take the lead from these
women to help dismantle and dispel myths, prejudices, and practices that they
perceive as harmful. Instead, by demonizing Islam and Arab culture broadly, FEMEN
only succeeds in strengthening the discrimination against Muslim/Arab women,
further silencing and isolating them.
How FEMEN Fails Feminism
It is telling that FEMEN’s Shevchenko, cannot conceive of a world in which
one exists simultaneously as a Muslim and a Feminist. In a 2013 interview,
Shevchenko told a reporter, “[Muslim feminism] cannot exist. It's oxymoronic. Once
any monotheistic religion is starting, feminism is finished. […] Muslim feminist,
Christian feminist, Jewish feminist, it's all oxymoronic.”
By clearly delineating the
boundaries of who can and cannot be feminist, FEMEN relies on colonialist rhetoric
that defines women as oppressed by culture and religion, while no mention is made
of intersectional concerns of capitalism, racism, or global imperialism.
Constructing culture as a barrier to women’s personal liberty reveals a
liberal understanding of “freedom” – on a personal, individual level – that is
idealized and achieved as the direct result of the elimination of cultural practices.
Again, this fails to consider the possibility of women using cultural notions as a
means of fighting oppression. In this case, FEMEN defaults to promoting the idea
that Muslim women are suffering from “false consciousness” because they cannot
see that the veil and religion are intrinsically harmful to all women. The other side of
that message is that FEMEN can see, however, and it is more than ready to show the
poor, oppressed Muslimahs how misguided they are.
FEMEN’s Topless Jihad Day fails as a feminist demonstration by neglecting to
create a space for women to disagree with its narrow concepts of feminism,
freedom, and valid cultural experience. The campaign to “Free Amina” ended up
being little more than a publicity stunt for the group with Tyler as its prop,
evidenced by the fact that during the entire campaign, FEMEN “offer[ed] no solution
to the undeniable subjugation of women present in the Middle East-North Africa. [I]t
Aitkenhead, D., Femen leader Inna Shevchenko: ‘I’m for any form of feminism’. THE
GUARDIAN, November 8, 2013: http://bit.ly/1fu0vO6.
[was] all a show of thin, white grandeur.”
Emily Badcock puts forth a list of helpful
and supportive actions that FEMEN could have engaged in instead:
[A]s a starting point, campaign against the increasing militarisation of
East London, making it harder for Muslims to walk the streets without
harassment. They might join Muslim women in asserting the right to
wear hijab or niqab without fear of attack. Interestingly, activists in
the Revolutionary Association of Women in Afghanistan (RAWA) have
mentioned that the burqa can sometimes make it easier for them to
carry out political activity, as it can disguise political leaflets and
hidden cameras. FEMEN could listen to these women, the women they
are patronisingly attempting to 'save'.
SlutWalk: Another Mainstream Feminist Fail
Before Topless Jihad Day there was “SlutWalk.” SlutWalk was a protest
movement that started in Toronto, Canada in 2011 after a police officer told women
to avoid “dressing like sluts” if they wanted to prevent being sexually assaulted.
Women took to the streets in skimpy outfits in order to reclaim the word “slut” and
push back against the idea that a woman who takes a variety of sexual partners or
who presents herself in an alluring way is asking to be assaulted or deserving of
being debased. The SlutWalk movement spread to different cities including New
York, Los Angeles, London, and Washington, D.C. as women were emboldened by
the media attention and daring message – no more slut-shaming.
SlutWalks around the world were criticized for a slew of issues ranging from
the name of the movement to poor organization to the lack of any substantial
feminist messaging. “Slutwalk itself consistently refuses any connection to feminism
and fixates solely around liberal questions of individual choice — the palatable “I
Chamseddine, R., ‘FEMEN’ and the suppression of native voices. MONDOWEISS,
April 6, 2013: http://bit.ly/1meu9Fk.
Badcock, supra note 21.
SlutWalk Toronto. http://bit.ly/1kj4WXP
can wear what I want” feminism that is intentionally devoid of an analysis of power
dynamics,” wrote Canadian journalist, Harsha Walia.
Blogger Ada Farrugia Conroy
echoed the frustrations of many when she said, “slutwalk is a post feminist event. it
is an event that assumes there is no patriarchal context that slutwalk exists within.
the word ‘slut’ is hateful and violent and has never belonged to us. ‘slut’ belongs to
rapists and misogynists and pornographers. there is no subversion in this. this
action is not a threat.”
Beyond the general disappointment surrounding SlutWalk by feminists of
every ilk, another line of criticism emerged from women of color, specifically, who
saw SlutWalk as yet another way that mainstream, liberal feminism claimed to
speak on their behalf but failed to represent their experiences by only taking gender
into account as the most important variable. They insisted that their realities were
far more complex than the singular category of “woman”. As Professor Brittney
Cooper writes at the black feminist blog Crunk Feminist Collective:
But perhaps, we have come to a point in feminist movement-building
where we need to acknowledge that differing histories necessitate
differing strategies. […]
What becomes an issue is those white women and liberal feminist
women of color who argue that “slut” is a universal category of female
experience, irrespective of race. […] I’d prefer that white women
acknowledge that they are in fact organizing around a problematic use
of terminology endemic to white communities and cultures. In doing so,
this would force an acknowledgement that the experience of
womanhood being defended here–that of white women– is not
Walia, H., Slutwalk: To march or not to march. RABBLE.CA. May 18, 2011:
Conroy, A., What Offends me about SlutWalk, THE BROKEN ARTED. May 11, 2011:
universal, but is under attack and worthy of being defended, all the
Black Women’s Blueprint, a Brooklyn-based civil and human rights
organization penned an open letter to the organizers of SlutWalk which
encapsulated the arguments that WOC feminists had been making for decades:
We know the SlutWalk is a call to action and we have heard you. Yet
we struggle with the decision to answer this call by joining with or
supporting something that even in name exemplifies the ways in
which mainstream women’s movements have repeatedly excluded
Black women even in spaces where our participation is most critical.
We are still struggling with the how, why and when and ask at what
impasse should the SlutWalk have included substantial representation
of Black women in the building and branding of this U.S. based
movement to challenge rape culture?
It’s not difficult to see the connections between SlutWalk and some of FEMEN’s
demonstrations that, while well-intentioned, neglect to include the full range of
women’s lived experiences and as such, further oppresses, alienates, and silences
points of view that fall outside of the mainstream’s focus.
Solidarity is for White Women
Back in August 2013, the hashtag #SolidarityIsForWhiteWomen
worldwide on Twitter. Sparked by backlash toward Hugo Schwyzer, a so-called
Cooper, B., SlutWalks v. Ho Strolls. THE CRUNK FEMINIST COLLECTIVE. May 23,
Black Women’s Blueprint. An Open Letter from Black Women to the SlutWalk.
BLACK WOMEN’S BLUEPRINT. September 23, 2011: http://bit.ly/1mhQlhP.
See Ryan, E., Our Favorite #SolidarityIsForWhiteWomen Tweets [Updated].
JEZEBEL. August 13, 2013: http://bit.ly/R4AaL6.
white “male feminist” who, despite targeting and vilifying women of color online,
was defended and regarded prominently by white feminists (he was an early figure
in the organization of SlutWalk Toronto
). Twitter users criticized what they saw as
the exclusion of nonwhite women from mainstream feminism both in the emerging
world of digital feminism and in the traditional movement as well. One such tweet
by the user “RoadtoPalestine” directly addressed FEMEN’s Topless Jihad Day,
stating, “#SolidarityIsForWhiteWomen is when Femen gets to decide the Muslim
While many white, mainstream feminists have been open to hearing
criticisms like those around SlutWalk and the Solidarity Is For White Women
hashtag in attempts to be better allies, others have argued that such public discord
within the feminist movement is divisive and only serves the patriarchy. The
Huffington Post UK’s Adele Wilde-Blavatsky is one such feminist that has been
pushing back against what she sees as “white women bashing” by women of color:
To 'blacken' the name of the work and efforts of white women in the
feminist movement and to portray them as the 'enemy' of women of
colour is a great disservice not only to white women but also to
women in general. In addition, it only serves to further divide women
and empower patriarchy and misogyny. Seeing women blame each
other for issues related to patriarchy is tragic.
See Hamilton, T., On Hugo Schwyzer, White Supremacist Mainstream Feminism and
Its Abuse of Women of Colour. GRADIENT LAIR. August 12, 2013:
Jarvis, H., Hugo Schwyzer and SlutWalk. SLUTWALK TORONTO. August 22, 2013:
Farah (RoadToPalestine). “#SolidarityIsForWhiteWomen is when Femen gets to
decide the Muslim women's attire.” August 12, 2013, 12:34 p.m. Tweet.
Wilde-Blavatsky, A., Stop Bashing White Women in the Name of Beyonce: We Need
Unity Not Division. THE HUFFINGTON POST-UNITED KINGDOM. December 12, 2013:
Wilde-Blavatsky misses the point (especially with that unfortunate "blacken"
pun). She views women of color calling out white feminists for essentially erasing
them as "allow[ing] race and 'culture' to divide rather than unite women.”
reality is that race and culture will always be part of the equation and if that’s
inconveniencing to some mainstream feminists then the “unity” she speaks of
always sat on a shaky foundation.
The Intersectionality Imperative
I believe that the examples above illustrate that in order to truly speak for
and with women all over the world, feminism must be grounded in intersectionality.
The term “intersectionality” was coined by legal scholar and woman of color
Kimberlé Crenshaw in the 1980’s as a direct response to the exclusionary nature of
much of mainstream feminism.
Long thought to be the provenance of middle-class
white women, mainstream feminism has sort of an image problem:
[l]iberal feminism has been accused of being culturally imperialistic,
of reenacting the errors of orientalist thoughts, of obscuring the forces
that actually shape culture, and denying that women have agency
within patriarchy; of not taking into account that all cultures are
differently patriarchal, as well as characterized by resistance to
An intersectional feminism would require the examination of multiple layers of
identities in order to analyze how they interact with one another, in opposition to
the idea that gender is the sole or primary identity present in feminist analyses.
Nash, J., Re-thinking intersectionality. FEMINIST REVIEW 89.1 (2008).
Mancini, supra note 23.
Recognizing that feminism is limited by the construction of the priority of
issues around which all women (as a monolith) are expected to organize,
intersectionality provides an alternative that allows people’s lived experiences to be
taken into consideration – specifically how various marginalizations and positioning
intersect to create unique situations and priorities for women. By adopting anti-
racist, anti-homophobic, and anti-Islamophobic rhetoric, feminism has the potential
to be a truly emancipatory ideology and movement. What feminism cannot do,
however, is effectively ally with diverse, heterogeneous women if the only lens
through which patriarchy and oppression of women is viewed is itself grounded in
the experiences of white, Western, mainstream culture.
Instead of fighting oppression and joining together in upholding women’s
rights, FEMEN alienates themselves as white, paternalistic saviors who may be
doing more to fuel negative impressions of Westernized feminism instead of
furthering movement. Whereas FEMEN’s efforts to bring attention to Amina Tyler’s
predicament were well-intentioned and, on some level, necessary, their methods left
much to be desired. Racism, Orientalism, Imperialism, etc., is not feminism, or at
least it shouldn’t be. But the fact that it often plays out that way is the reason why
many women of color have trouble accepting it and why so many are afraid to
challenge patriarchy, lest they be confused with the “those feminists” over there.
When considering how FEMEN could have better helped Tyler and other
Muslim women trying to assert their humanity without resorting to tactics that
Mohanty, C., Under Western eyes: Feminist scholarship and colonial
discourses. FEMINIST REVIEW 30, (1988).
were racist and oppressive, critics have implored FEMEN to listen first: “[Y]ou raise
awareness by highlighting native voices, not co-opting them. It is your duty to
amplify, not commandeer.”
For anyone wishing to support a liberation movement
for a group they don’t belong to, the key is a thorough analysis of structural power,
and choosing to listen instead of lead. Feminist solidarity is crucial but a Topless
Jihad is not the way to do it. A true ally does not use racism to attempt to defeat
Intersectionality is becoming increasingly popular as a theory in academia
but we need it to be popular in practice as well. Women of color must be granted
their rightful seat at the table so that we can work together to dismantle patriarchy
and other institutions that prevent us from fully realizing life and liberty. With that
seat at the table comes the space to criticize mainstream feminists who, through the
best of intentions, fail to include or consider the multi-layered impact of their
actions on peoples of color around the world whose lived experiences might fall
outside of the norms dictated by Western culture.
I close with words from Roxane Gay, a Black feminist author, that I feel
encapsulate the imperative of an intersectional feminism for the survival of the
movement as a whole:
We have a painful, infuriating history to reconcile — one where the
concerns of heterosexual, able middle-class white women have too
often been privileged at the expense of everyone else.
Intersectionality is an awkward word representing an important idea.
While feminism is the belief that the rights of women are as
inalienable as the rights of men, feminism, at its best, is so much more.
No one assumes only one identity. We cannot consider the needs of
women without also accounting for race, ethnicity, gender,
Chamseddine, supra note 29.
citizenship, class, sexuality, ability and more. Such nuanced
awareness, such intersectionality, is the marrow within the bones of
feminism. Without it, feminism will fracture even further.
Demby, G. Twitter Sparks a Serious Discussion About Race and Feminism. NPR
CODE SWITCH. August 23, 2013: http://n.pr/SeEubF.
This action might not be possible to undo. Are you sure you want to continue?