Professional Documents
Culture Documents
William Venneberg
Professor Smith
English 102
May 9 2021
Research Paper
The freedom of the press from legislative regulation and censorship is one of the
principle foundations on which American society has built its enduring structures. A free press
serves as a check on the actions of the governing bodies to call attention to their misactions. The
nature of such a free press within America can be said to have experienced both little and great
shifts within its lifetime, and both statements would be true. In the scope of any individual news
outlet, the shift has been of great change; now, unlike at the time of America’s birth, one news
outlet can reach all corners of the nation within hours, if not minutes, of a story’s happening. The
information from individual papers and channels is consumed by millions of people daily. But
with regards to how an outlet operates interiorly, there has been little change at all. The
producers of the news are still fallible and driven by their own motivations. To viewers and
readers, these motivations are perceived, and in their being perceived, deter individuals who see
cause to distrust, attract individuals who distrust and seek to critique, and, most importantly,
attracts individuals who have been alienated elsewhere. These corresponding effects are by no
means new to the social patterns of Americans; they have occurred at varying degrees throughout
the history of news sources. But today, they are simultaneously caused by the political divides
within America and contribute in turn to the divides through the creation of distinct channels of
information.
Venneberg 2
Some contend whether the topic of bias within the news media is an issue at all. In his
article “The Rise of Partisan Media Is Not Accountable for the Growing Political Polarization,”
author Kevin Arceneaux suggests, “People tune in to partisan news because they are partisans.
Even without partisan news media, these individuals would likely interpret the world through a
partisan lens” (Arceneaux). Arceneaux suggests that it was likely political polarization that has
led to partisan media not vice versa. The concession ought to be made that this can very well be
the case. While one can question Arceneaux’s evidence as it was limited mainly to television
However, the article’s suggestion that polarization does not occur in turn is subject to
scrutiny. A failure to report significant news stories, or even significant supporting details, can
affect the perception left on the viewer just as much as a lie told to them. Where the latter might
push the viewer towards partisanship, extending the general position of the viewer to the political
extreme being favored by the outlet, the former could be said to diminish the room for common
ground between the two political sides by limiting the availability of facts on which a basis for
agreement can be built. Both lead to distinct divides within the United States, but while pushes
toward radicalism are dangerous, a diminishing area where people can unite is a frightening
notion, nonetheless.
Several studies also indicate the viewers themselves believe media bias, at least perceived
media bias, is responsible for the partisan divide in the U.S. An infographic provided by Gale
and based on information gathered by Gallup and the Knight Foundation indicates this by
showing how people divided by race, gender, and political affiliation attribute blame to the news
media. According to the infographic titled Opinions among US Adults Regarding the News
Media’s Responsibility for Political Divisions and News Bias, 2019, there are disparities in how
Venneberg 3
much blame is attributed between demographics, but of all respondents in each group, 47%
attribute “a great deal of blame” and another 36% attribute “a moderate amount of blame” for
political divisions to news outlets (Gale). One could say that 83% of people believing the media
is at least partially to blame for divisions is significant and constitutes a problem. An opponent
might argue that this is argumentum ad populum, and therefore is insufficient as evidence that
the problem exists. This critique is correct in that the use of these statistics is an appeal to
numbers, but the conclusion ought to be contested until it is at least in doubt. This discussion
concerns individuals’ habits, habits which are governed not by truths but by those individuals’
perceptions. For this reason, statistics that describe the number of individuals who blame media
bias for political divisions is at least a window into the issue at hand.
With the determination that a majority of Americans attribute blame to the news media
for political divides, and thus establishing the existence of an issue, a determination as to what
direction the implications of this issue tend ought to be made. Ignoring for the moment the
claims of defamation made by outlets on each side being directed at outlets on the opposing side
in efforts to discredit them, there are polls that indicate how biased the public perceives the
media to be. According to a Gallup article written by Lymari Morales from 2011, of the 60% of
Americans who observed bias within the media, 47% viewed the media as too liberal (Morales).
The numbers of more specific groups are more telling with 57% of Democrats believing the
media is “just about right” and Republicans and independents perceiving the media to be too
liberal at 75% and 50% respectively (Morales). This belief on the right that generally the media
is too liberal, an idea that is substantiated by the views of independents, makes the practices of
partisan individuals more understandable. According to the Pew Research report “Political
Polarization & Media Habits,” individuals who are consistently more conservative tend to use
Venneberg 4
Fox News as their primary news source for politics at 47% while individuals who are
consistently more liberal, who presumably see the bias of the general media more favorably, tend
to vary in what they depend mainly on for political news (Mitchell et al.). It is understandable
that an individual who might feel alienated by most media outlets for their personal stances
would not tend to frequent them for their news lest the feeling of alienation persist instead
preferring news outlets that already portray news in a way similar to their own beliefs. For this,
the news outlets would need to have already been established with their particular biases. This is
how political divides cause partisan news in agreement with Arceneaux. Already established,
political demographics provide sources of viewers that news outlets would conform to in order to
provide themselves with a reliable base. Such is the nature of markets. While this surmise is open
avoid news outlets that portray news in a way dissimilar to the viewer’s personal beliefs, as it
stands, it seems rational enough to continue this line of reasoning. Should any individual be in
doubt of the reality of this notion, perhaps a reflection on how often they seek to disprove their
own beliefs would be sufficient to convince them that humans tend to favor their convictions
With the determination that political polarization contributes to bias in the media, how
biased media contributes in its turn to political polarization can be discussed. The article
“Distorting the News? The Mechanisms of Partisan Media Bias and Its Effects on News
Production” by Doron Shultziner and Yelena Stukalin illustrates two general methods by which
partisan media influences its readers, each possessing more exact classifications. The first
method is described as “description bias” or “content bias” and is probably the more significant
and recognized form (Shultziner and Stukalin). According to the article, this form of bias
Venneberg 5
includes what events papers choose to report on as well as how they choose to describe the
events in the articles and headlines (Shultziner and Stukalin). Actual bias within what a news
outlet decides to report on may be difficult to determine as different editors may believe that
certain stories hold more worth in their publication. Regardless, news outlets of one political
leaning will occasionally question the failure of outlets of the opposing political leaning to cover
a particular story and, in doing so, will attribute motive, an objectionable practice that further
deters individuals from the other media outlets. One such example of this dividing practice can
be found from Fox News on April 15th of this year. In his article which addresses the topic of
court-packing, Fox News writer Joseph A. Wulfsohn does just this by claiming the generalized
“mainstream media” will use Justice Ruth Bader Ginsburg’s wish that Trump not nominate her
replacement because it suited them but will ignore her position that she was “not at all in favor of
conservative favoring split of the Supreme Court being 6-3 because it did not suit their position
(qtd. in Wulfsohn). While the fact that the generalized ‘mainstream media’ only used Ginsburg’s
position when it suited their stances is potentially true, the attribution of such a motive is not a
practice to be done within a civil society. It only divides and is akin to childish finger pointing.
The second kind of content bias which concerns how stories are portrayed, in contrast to the
largely subjective nature of the first, can show itself to be starkly evident when it does occur. A
relatively well-known example of this occurred in August of 2020 when, as an article from The
Hill describes, “CNN was ridiculed for a video caption . . . that read ‘Fiery But Mostly Peaceful
Protests After Police Shooting’ . . . in front of a building engulfed in flames during protests over
the shooting of Jacob Blake in Kenosha” (Concha). The words “Mostly Peaceful,” in this
example, are misleading. While it is entirely possible that a majority of attendants acted
Venneberg 6
peacefully, the reality is that events come to be defined by most shocking details. Take, for
example, another event turned violent: the January 6th riot at the capitol. According to an
Associated Press article, approximately 25,000 attendants were at Trump’s rally while only 800
broke into the Capitol Building (Associated Press). If these numbers are accurate, the only 3.2%
of the attendants turned violent; however, it would be disingenuous to downplay the events of the
riot by emphasizing how relatively few individuals participated in it. The insurrection and the
rally are separate events; to conflate the two is dishonest. Similarly, the protests and the riots in
the CNN byline are different. The peace of one does not justify the violence of the other. This
form of media bias concerning what articles contain, of which the CNN example is but one of
countless of varying degrees of blatancy, can be found often in the chosen adjectives used within
an article or byline and is likely to hold the most significance because an individual is more
likely to favor the first source of news they encounter due to first impression bias. With regards
to only the misleading headlines of articles, individuals lacking free time will only skim article
headlines before dedicating themselves to one that strikes their interest. Those headlines that are
read but whose articles are passed by do not leave the reader without impression, however small
it may be.
The second form of media bias according to Shultziner and Stukalin’s article occurs in
editing and occurs particularly in print. This form is not given a particular name in the same way
the first form was as it is less exact and far more subtle. According to “Distorting the News? The
Mechanisms of Partisan Media Bias and Its Effects on News Production,” this second form
concerns how specific stories are highlighted within a newspaper, be it their being featured on
the first page, their being hidden away in the back, and even concerning the size of the area being
dedicated to the article (Shultziner and Stukalin). Again, actual bias using this mechanism is
Venneberg 7
difficult to determine as it is understandable that an editor would choose to feature a story that
grabs attention while hiding away one less interesting, but that is not to say that a paper cannot
influence the opinions of their readers based on what stories are featured. This bias in how
individual stories is highlighted could be considered as a diluted form of the first form of content
bias: instead of merely ignoring newsworthy stories, they are simply hidden away. An example
of this will not be included, however, as actual bias is difficult to determine as well as the fact
The two practices of media bias described by Shultziner and Stukalin, while holding
some ability to manipulate the viewers, are relatively minor in their significance and results.
There are, however, instances that sway their viewers so widely as to have real world
consequences. These consequences are partially to blame on individual’s habits to frequent only
one or a few news sources with slants parallel to one’s own. An individual caught up in an echo
chamber of similar ideas allows similar viewpoints to be repeated by multiple sources until they
take root in the viewer’s mind and manifest as actions and voiced opinions. This, however,
depends on one’s trust in their sources of media as well as the number of trusted sources
repeating the same position. The more one believes in what their news outlet is telling them and
the more outlets that repeat the same talking points, the more likely an individual is to allow such
Trust in the media is generally low. According to a Gallup report titled “Americans
Remain Distrustful of Mass Media,” only 40% of respondents trusted the media a “great deal” or
a “fair amount” in 2020 (Brenan). When comparing political parties, the contrast is stark with
73% of Democrats trusting the media a “great deal” or a “fair amount” and independents and
Republicans at 36% and 10% respectively (Brenan). These numbers, while showing the trust
Venneberg 8
individuals have of the media in general, they do not address the divided channels of particular
media sources. For that, the report cited earlier from the Pew Research Center titled “Political
Polarization & Media Habits” provides additional insight. According to that report, individuals
who are “mostly conservative” and “consistently conservative” tend to reserve their trust to
outlets that individuals being “mostly liberal” and “consistently liberal” hold “more distrust than
trust” in (Mitchell et al.). Such programs as these include, according to the report, Fox News,
The Sean Hannity Show, The Glenn Beck Program, and The Rush Limbaugh Show, among
other, lesser-known outlets (Mitchell et al.). This pattern of conservatives trusting outlets that
liberals distrust is also reversed at times as is the case with the New York Times, The
Washington Post, MSNBC, and, to a lesser extent, CNN (Mitchell et al.). These well
distinguished channels of trusted news sources focus particular, parallel positions in a way unlike
In his 1835 book, Democracy in America: Vol.1, Alexis de Tocqueville comments on the
freedom of the press in America. One observation that he makes concerns the sheer numbers of
papers, each with its own purposes (Tocqueville 177). As he puts it, “It is not that all the political
newspapers in the Union are ranged for or against the administration; but they attack it and
defend it by a hundred diverse means” (Tocqueville 177). Tocqueville describes this as a boon
for it prevents the general media from establishing “great currents of opinion” which, united,
could flood away the most fundamental structures of American society (177). Even a few
decades ago, there were respected individuals from which people on both sides of the aisle
received their news. Anchors like Walter Cronkite provided all politically divided Americans
with the same information and allowed discourse to begin on equal, informational footing. But
such great currents have arguably arrived; however, as the Pew Research report before describes,
Venneberg 9
they have come as two distinct channels. Each with its own base, each with its own pull, and
The power of both channels of information have each shown themselves in differing
manners. It must also be kept in mind that the influence of each one is dependent on the methods
of media bias described by Shultziner and Stukalin, but also a more extreme method: a
dependance on factually unsound claims on news stories which goes beyond the manipulation of
news to full deception, either willfully malicious or willfully ignorant. Tocqueville observed that
individuals did not read newspapers for the opinions of the writer but for “knowledge of the
facts” (178). This sentiment seems to persist still today; individuals may want to hear the
opinions of people they admire like Oprah or the president, potentially even news personalities
that serve the dual role of presenting news and then providing engaging commentary, but
individuals watch the news to hear reality so they can form opinions of their own. For this
reason, Tocqueville also cautions that, “it is only in altering or in denaturing the facts that the
journalist can acquire some influence for his opinion” (178). This too persists, and ought to be
watched for carefully. Examples of these cases, like the examples of those for the methods of
media bias for Shultziner’s and Stukalin’s forms, are plentiful. A thorough list of examples
would be arduous and an inefficient use of time. Therefore, only two specific and relatively
recent examples will be described, each originating from its own great channel of information.
The first example concerns the claims of voter fraud and vote irregularities in key
battleground states. Such allegations persisted in conservative news outlets for months after the
election. The Washington Post, in a video it uploaded to YouTube, shows a compilation of Fox
News commentators perpetuating these claims of voter fraud and vote irregularities on their
show (Washington Post). Such allegations, persisting in conservative news outlets for months
Venneberg 10
after the election, are likely to have, in tandem with individuals’ repetition of such claims on
social media platforms, led to the events on Capitol Hill on January 6th. While this correlation is
easily presumable, the role the media played in it is not exact and lacks sufficient, inarguable
evidence. Moreover, the events led to a moment, if only briefly, where individuals of both
political leanings denounced in unison the use of violence in this event. As a better example of
the divide among Americans, the court case Texas v. Pennsylvania can be turned to. This case,
according to the bill of complaint, was a lawsuit from the state of Texas against The
Commonwealth of Pennsylvania, and the states of Georgia, Michigan, and Wisconsin for
“significant and unconstitutional irregularities” in the defendant states, irregularities which had
been the focal point of conservative networks for weeks after the presidential election (United
States, Supreme Court, “Bill of Complaint” 3-4). This court case was never heard by the
Supreme Court of the United States, but the divide between Americans was made clear when
seventeen other states filed Amici Curiae briefs stating their support for the plaintiff, Texas, in its
lawsuit (United States, Supreme Court, “State of Missouri and 16 other States” 1). Others filed
separately in support of the defendants, and representatives in state and federal legislatures filed
in support of both sides, some in favor of Texas coming from the defendant states themselves
(United States, Supreme Court, “Bryan Cutler and . . . Kerry Benninghoff”). The split was clear
between those who were suspicious of the events of the election due to news stories of vote
irregularities, and those who saw no reason for suspicion. The sources of information, being
conservative vs. liberal, contributed greatly to this divide through what they reported and how
The second example is even more recent. In March of this year, Georgia passed SB 202
or the Election Integrity Act of 2021. From the gate, it received avid criticism. One such voice of
Venneberg 11
condemnation came from CNN’s Don Lemon during his show. In his segment, Don Lemon
makes several claims concerning the Georgia voting law, many of which can be discredited upon
examination of the law itself. Firstly, Lemon claims that the bill is “just out and out racist” (7:53-
55) and “it is no different than Jim Crow” (8:55-9:00). Such rhetoric is divisive in its own right,
but mere division is not the significance of this news story, misrepresentation is. To equate SB
202 to Jim Crow is firstly a failure to represent the evils of Jim Crow. Upon examination of the
racist laws of the post-reformation south, one can clearly see how they issued different rules for
individuals on the basis of differing skin tones (Jim Crow Museum of Racist Memorabilia). This
is wholly unlike SB 202 which sets the same requirements for every voter of the state of Georgia.
Furthermore, Don Lemon makes claims that address specific aspects of SB 202. One claim made
is that the bill forbids “giving food or water to a voter waiting in line” illegal (Lemon, 4:22-30).
This claim refers to section 33 of the bill which forbids “the giving of any money or gifts . . .
[w]ithin 150 feet” of the polling building for the prevention of electioneering. This does not
forbid a voter to leave the 150-foot radius to get water, nor does it forbid, as the bill expressly
mentions, “making available self-service water from an unattended receptacle” for the voters in
line (Burns 73-74). Another claim of Lemon’s is that the bill “allow[s] unlimited challenges to
voter registrations” (4:29-34). This is true in the way the bill does not specify a limit to the
number of challenges within the section being addressed, section 15. But an omission of a
limiting parameter is not cause for concern as the abuse of this rule is impractical because the bill
specifies “The burden shall be on the elector making the challenge to prove” to a deciding judge
that the voter is ineligible, and the voter retains the right to appeal the decision should the judge
rule unfavorably (Senator Burns 24). This criticism of the failure to include a limiting parameter
would be a respectable one if Lemon had only framed it in such a way. Lemon also turns to
Venneberg 12
President Biden to repeat other verifiably false claims such as the bill ends voting at 5pm and
absentee ballots except “under the most rigid circumstances” and fails to correct the President’s
misguided words, instead agreeing with him (6:53-7:30). The section mentioning 5pm, section
28, does little, if anything, to change the previously existing law. SB 202 merely changes the
general term “normal business hours” to “beginning at 9:00 A.M. and ending at 5:00 P.M.”
(Senator Burns 59). Furthermore, employers are already required to provide their employees with
“any necessary time off from his or her employment to vote” in any election or primary
according to Georgia State Code (Georgia). As for the concerns of absentee ballot restrictions,
these likely refer to SB 202’s decrease of drop boxes and the identification requirements. In the
bill’s second section, it is explained that “drop box[s] were first created by the State Election
Board as a pandemic response” (Georgia 5). The voting bill does not eradicate drop boxes, but
because their need will diminish as the threat of Covid wanes, Georgia’s Election Integrity Act
of 2021 saw it appropriate to diminish the number of drop boxes. The ID requirement, however,
is more controversial considering that some demographics are less likely to possess photo IDs
than others. The bill includes an identification requirement for an application to receive an
previously relied solely on (Burns 4). But SB 202 does not limit absentee applicants to the
identifications of driver’s licenses, passports, and the state’s free IDs. If a voter lacks such
identifications as well as a social security number, the bill allows for the use of “a copy of a
current utility bill, bank statement, government check, paycheck, or other government document
that shows the name and address of such elector” (Georgia 58 & 64). It is presumable that any
potential voter will possess at least one of these forms of identification; the Georgia legislature
appears to have sought to ensure that the requirements can be met by anyone needing to. But as a
Venneberg 13
final safeguard, should an application for an absentee ballot be received without such forms of
identification, a provisional ballot will be issued to allow officials time to verify the identity of
the applicant (Georgia 64). Don Lemon’s condemnation of Georgia’s Election Integrity Act of
2021 was only one of many. A criticism of a law is understandable. It can even be sufficiently
argued that it is the very point of a free press. But anchors and news articles that misrepresent
stories can have significant, real world results. Due to the controversy spurred by voices
repeating misguided outrage over SB 202, Major League Baseball decided to relocate its All-Star
game out of Atlanta. According to Natasha Chen, Melissa Alonso, and Alaa Elassar, the move
will have an economic impact of approximately $100 million dollars for the predominantly
African American city (Chen et al.; United States Census Bureau). Although such a result was
certainly not the intention of the press, the misrepresentation of the story led to such a result,
nonetheless.
Both of these examples, particularly their results, were not solely the fault of distinct
channels of trusted news. Both outcomes were also fostered by the words of the sitting presidents
as well as citizens exercising their freedom of speech on social media platforms. Furthermore,
mere distrust in the news media is not sufficient because even when one distrusts a news source,
if they limit themselves to that source, significant information and stories may still never be
heard. More civil discourse is needed within the United States; that is for certain. And it is not
solely the fault of partisan news media that civility can be found lacking within American
society. Its divides are perpetuated through individuals’ actions. Individuals cause partisan media
and it, in turn, divides them. Additionally, there are numerous other causes of the divisions in the
United States. These include the echo chambers one can find themselves in on social media,
flaws in algorithms that inadvertently guide internet searches, individuals who fund groups they
Venneberg 14
favor, various cultural and regional differences, and even an individual’s tendencies to associate
with individuals of opposing viewpoints or not. None of these solely influence the current state,
and it is their combined effects that have led us to the current divisions. One must not forget that
the complexities of this issue are not limited to what news outlets one patronizes. But what can
be done? Change cannot come except through national, cultural reforms. Since the needed
change is so vast, it is unlikely to come anytime soon. But nations and societies are made up of
individuals working and living and thriving together. Change will not come when the focus is
directed on a national scale, but it can come gradually when each individual turns that focus
towards self-improvement. One must be vigilant and watch their own trusted media for signs of
bias. One must expand their horizons in an effort to understand the concerns of their opponents
and to hear new information. One must take the initiative and investigate the source material of
stories that concern them most. News outlets will not stop being biased until they are made to see
that their viewers will not tolerate dishonesty, and such a change starts with how everyday
Works Cited
pro-trump-rioters-invaded-capitol/.
Arceneaux, Kevin. "The Rise of Partisan Media Is Not Accountable for the Growing Political
link.gale.com/apps/doc/EJ3010958215/OVIC?u=nilrc_bhc&sid=OVIC&xid=c2d4300c.
Accessed 16 Apr. 2021. Originally published as "Why You Shouldn't Blame Polarization
on Partisan News," Washington Post, 4 Feb. 2014. Gale Document No.: EJ3010958215
Brenan, Megan. “Americans Remain Distrustful of Mass Media.” Gallup, 30 Sept. 2020,
news.gallup.com/poll/321116/americans-remain-distrustful-mass-media.aspx.
legis.ga.gov/api/legislation/document/20212022/201498.
Chen, Natasha, et al. “MLB's decision to move its All-Star Game out of Georgia will have a
$100 million impact on the state, tourism official says.” CNN, 3 Apr. 2021,
cnn.com/2021/04/03/us/mlb-all-star-game-relocation-lost-money-economic-
impact/index.html.
Concha, Joe. “CNN ridiculed for 'Fiery But Mostly Peaceful' caption with video of burning
cnn-ridiculed-for-fiery-but-mostly-peaceful-caption-with-video-of-burning.
Georgia. Georgia Code. Title 21, section 21-2-404. E laws.US, 20 Aug. 2013,
ga.elaws.us/law/section21-2-404.
Venneberg 16
Jim Crow Museum of Racist Memorabilia. “Examples of Jim Crow Laws - Oct. 1960 - Civil
ferris.edu/HTMLS/news/jimcrow/links/misclink/examples.htm.
Lemon, Don. “'Are you outraged?': See Don Lemon's reaction to lawmaker's arrest.” CNN, 2021,
cnn.com/videos/politics/2021/03/26/georgia-voting-bill-don-lemon-sot-vpx-ctn.cnn.
Mitchell, Amy, et al. “Political Polarization & Media Habits.” Pew Research Center: Journalism
Morales, Lymari. "Majority in U.S. Continues to Distrust the Media, Perceive Bias; More
perceive liberal bias than conservative bias." Gallup Poll News Service, 22 Sept. 2011.
A268427085
"Opinions among US Adults Regarding the News Media's Responsibility for Political Divisions
and News ..." Gale Opposing Viewpoints Online Collection, Gale, 2021. Gale In
JFXETH676431690
Shultziner, Doron, and Yelena Stukalin. “Distorting the News? The Mechanisms of Partisan
Media Bias and Its Effects on News Production.” Political Behavior, vol. 43, issue 1,
Tocqueville, Alexis de. “On Freedom of the Press in the United States.” Democracy in America.
United States Census Bureau. “QuickFacts Atlanta city, Georgia.” United States Census Bureau,
United States, Supreme Court. “Texas v. Pennsylvania: Brief of State of Missouri and 16 other
States as Amici Curiae in Support of Plaintiff’s Motion for Leave to File Bill of
supremecourt.gov/DocketPDF/22/22O155/163215/20201209144840609_2020-12-
09%20-%20Texas%20v.%20Pennsylvania%20-%20Amicus%20Brief%20of
%20Missouri%20et%20al.%20-%20Final%20with%20Tables.pdf.
United States, Supreme Court. “Texas v. Pennsylvania: Motion for Leave to File Brief as Amici
Curiae Brief and Brief for Bryan Cutler, Speaker of Pennsylvania House of
supremecourt.gov/DocketPDF/22/22O155/163389/20201210145527909_Motion%20and
%20Brief%20House%20Leaders%20SCOTUS%20Amicus%20Texas%20v%20Pa%20et
%20al.pdf.
United States, Supreme Court. “Texas v. Pennsylvania: Motion for Leave to File Bill of
texasattorneygeneral.gov/sites/default/files/images/admin/2020/Press/SCOTUSFiling.pdf
Washington Post, The. “Trump allies allege widespread voter fraud then refuse to provide
Wulfsohn, Joseph A. “Media ignores RBG objection to court-packing after hyping 'dying wish'
to keep seat vacant before election.” Fox News, 15 April 2021, foxnews.com/media/ruth-
bader-ginsburg-supreme-court-dying-wish-court-packing.