rebellion

At the center of the sprawling legal battle over President Trump’s domestic military deployments is a single word: rebellion.

To justify sending the National Guard to Los Angeles and other cities over the outcry of local leaders, the Trump administration has cited an obscure and little-used law empowering presidents to federalize soldiers to “suppress” a rebellion, or the threat of one.

But the statute does not define the word on which it turns. That’s where Bryan A. Garner comes in.

For decades, Garner has defined the words that make up the law. The landmark legal reference book he edits, Black’s Law Dictionary, is as much a fixture of American courts as black robes, rosewood gavels and brass scales of justice.

The dictionary is Garner’s magnum opus, as essential to attorneys as Gray’s Anatomy is to physicians.

Now, Black’s definition of rebellion is at the center of two critical pending decisions in cases from Portland, Ore., and Chicago — one currently being reheard by the 9th Circuit and the other on the emergency docket at the Supreme Court — that could unleash a flood of armed soldiers into American streets.

That a dictionary could influence a court case at all owes in part to Garner’s seminal book on textualism, a conserative legal doctrine that dictates a page-bound interpretation of the law. His co-author was Antonin Scalia, the late Supreme Court justice whose strict originalist readings of the Constitution paved the way for the court’s recent reversal of precedents on abortion, voting rights and gun laws.

On a recent weekday, the country’s leading legal lexicographer was ensconced among the 4,500 some-odd dictionaries that fill his Dallas home, revising the entry for the adjective “calculated” ahead of Black’s 13th Edition.

But, despite his best efforts not to dwell on the stakes of his work, the noun “rebellion” was never far from his mind.

Federal authorities stand guard at an Immigration and Customs Enforcement facility in Portland, Ore., that has been the site of protests against the Trump administration.

(Sean Bascom / Anadolu via Getty Images)

“One of the very first cases citing my book sent a man to his capital punishment,” he explained of an earlier dictionary. “They cited me, the guy was put to death. I was very disturbed by that at first.”

He managed his distress by doubling down on his craft. In its first 100 years, Black’s Law Dictionary was revised and reissued six times. From 1999 to 2024, Garner produced six new editions.

“I work on it virtually every day,” he said.

Most mornings, he rises before dawn, settling behind a desk in one of his three home libraries around 4 a.m. to begin the day’s defining.

That fastidiousness has not stopped the lexical war over his work in recent months, as judges across the country read opposite meanings into “rebellion.”

The Department of Justice and the attorneys general of California, Oregon and Illinois have likewise sparred over the word.

In making their case, virtually all have invoked Black’s definition — one Garner has personally penned for the last 30 years. He began editing the 124-year-old reference book in 1995.

“The word ‘rebellion’ has been stable in its three basic meanings in Black’s since I took over,” he said.

“Ooo! So at some point I added, ‘usually through violence,’” he amended himself.

This change comes from the definition’s first sense: 1. Open, organized, and armed resistance to an established government or ruler; esp., an organized attempt to change the government or leader of a country, usu. through violence.

States have touted this meaning to argue the word rebellion cannot possibly apply to torched Waymos in Los Angeles or naked bicyclists in Portland.

The Trump administration, meanwhile, has leaned on the second and third senses to say the opposite.

The California Department of Justice wrote in its amicus brief to the Supreme Court in the Illinois case that federal authorities argue rebellion means any form of “resistance or opposition to authority or tradition,” including disobeying “a legal command or summons.”

“But it is not remotely plausible to think that Congress intended to adopt that expansive definition,” the state said.

Secretary of Defense Pete Hegseth walks onstage to deliver remarks as part of the Marine Corps’ 250th anniversary celebration at Camp Pendleton on Oct. 18.

(Oliver Contreras / AFP via Getty Images)

Although the scope and the stakes of the rebellion fight make it unique, the debate over definitions is nothing new, experts say.

The use of legal dictionaries to solve judicial problems has surged in recent years, with the rise of Scalia-style textualism and the growing sense in certain segments of the public that judges simply make the law up as they go along.

By 2018, the Supreme Court was citing dictionary definitions in half of its opinions, up dramatically from prior years, according to Mark A. Lemley, a professor at Stanford Law School.

Splitting hairs over what makes a rebellion is a new level of absurdity, he said. “This is an unfortunate consequence of the Supreme Court’s obsession with dictionaries.”

“Reducing the meaning of a statute to one (of the many) dictionary definitions is unlikely to give you a useful answer,” he said. “What it gives you is a means of manipulating the definition to achieve the result you want.”

Garner has publicly acknowledged the limits of his work. Ultimately, it’s up to judges to decide cases based on precedents, evidence, and the relevant law. Dictionaries are an adjunct.

Still, he and other textualists see the turn to dictionaries as an important corrective to interpretive excesses of the past.

“The words are law,” Garner said.

Law enforcement officers watch from a ledge of an Immigration and Customs Enforcement facility as a protester stands outside in an inflatable frog costume on Oct. 21 in Portland, Ore.

(Jenny Kane / Associated Press)

Judges who cite dictionaries are “not ceding power to lexicographers,” he argued, but simply giving appropriate heft to the text enacted by Congress.

Others call the dictionary a fig leaf for the interpretive excesses of jurists bent on reading the law to suit a political agenda.

“Judges don’t want to take personal responsibility for saying ‘Yes, there’s a rebellion’ or ‘no, there isn’t,’ so they say ‘the dictionary made me do it.’” said Eric J. Segall, a professor at Georgia State University College of Law. “No, it didn’t.”

Though he agreed with Black’s definition of rebellion, Segall rejected the idea it could shape jurisprudence: “That’s not how our legal system works,” he said.

The great challenge in the troops cases, legal scholars agree, is that they turn on a vague, century-old text with no relevant case law to help define it.

Unlike past presidents, who invoked the Insurrection Act to combat violent crises, Trump deployed an obscure subsection of the U.S. code to wrest command of National Guard troops from state governors and surge military forces into American cities.

Before Trump deployed troops to L.A. in June, the law had been used only once in its 103-year history.

With little interpretation to oppose it, the Justice Department has wielded its novel reading of the statute to justify the use of federalized troops to support immigration arrests and put down demonstrations.

Administration attorneys say the president’s decision to send soldiers to Los Angeles, Portland and Chicago is “unreviewable” by courts, and that troops can remain in federal service in perpetuity once called up, regardless of how conditions change.

Border Patrol official Greg Bovino marches with federal agents to the Edward R. Roybal Federal Building in Los Angeles on Aug. 14.

(Carlin Stiehl / Los Angeles Times)

Judges have so far rejected these claims. But they have split on the thornier issues of whether community efforts to disrupt immigration enforcement leave Trump “unable with the regular forces to execute the laws” — another trigger for the statute — and if sporadic violence at protests adds up to rebellion.

As of this week, appellate courts also remain sharply divided on the evidence.

On Oct 23, Oregon claimed the Department of Justice inflated the number of federal protective personnel it said were detailed to Portland in response to protests to more than triple its actual size — a mistake the department called an “unintended ambiguity.”

The inflated number was repeatedly cited in oral arguments before the 9th Circuit and more than a dozen times in the court’s Oct. 20 decision allowing the federalization of Oregon’s troops — an order the court reversed Tuesday while it is reviewed.

The 7th Circuit noted similar falsehoods, leading that court to block the Chicago deployment.

“The [U.S. District] court found that all three of the federal government’s declarations from those with firsthand knowledge were unreliable to the extent they omitted material information or were undermined by independent, objective evidence,” the panel wrote in its Oct 11 decision.

A Supreme Court decision expected in that case will probably define Trump’s power to deploy troops throughout the Midwest — and potentially across the country.

For Garner, that decision means more work.

In addition to his dictionaries, he is also the author of numerous other works, including a memoir about his friendship with Scalia. In his spare time, he travels the country teaching legal writing.

The editor credits his prodigious output to strict discipline. As an undergrad at the University of Texas, he swore off weekly Longhorns games and eschewed his beloved Dallas Cowboys to concentrate on writing, a practice he has maintained with Calvinist devotion ever since.

“I haven’t seen a game for the last 46 years,” the lexicographer said, though he makes a biannual exception for the second halves of the Super Bowl and college football’s national championship game.

As for the political football with Black’s “rebellion,” he’s waiting to see how the Illinois Guard case plays out.

“I will be looking very closely at what the Supreme Court says,” Garner said. “If it writes anything about the meaning of the word rebellion, that might well affect the next edition of Black’s Law Dictionary.”

Three of the country’s most powerful judges met in Pasadena on Wednesday for a rare conclave that could rewrite the legal framework for President Trump’s expansive deployment of troops to cities across the United States.

The move to flood Los Angeles with thousands of federalized soldiers over the objection of state and local leaders shocked the country back in June. Five months later, such military interventions have become almost routine.

But whether the deployments can expand — and how long they can continue — relies on a novel reading of an obscure subsection of the U.S. code that determines the president’s ability to dispatch the National Guard and federal service members. That code has been under heated debate in courts across the country.

Virtually all of those cases have turned on the 9th Circuit’s decision in June. The judges found that the law in question requires “a great level of deference” to the president to decide when protest flashes into rebellion, and whether boots on the ground are warranted in response.

On Wednesday, the same three judge panel — Jennifer Sung of Portland, Eric D. Miller of Seattle and Mark J. Bennett of Honolulu — took the rare move of reviewing it, signaling a willingness to dramatically rewrite the terms of engagement that have underpinned Trump’s deployments.

“I guess the question is, why is a couple of hundred people engaging in disorderly conduct and throwing things at a building over the course of two days of comparable severity to a rebellion?” said Miller, who was appointed to the bench in Trump’s first term. “Violence is used to thwart the enforcement of federal law all the time. This happens every day.”

The question he posed has riven the judicial system, splitting district judges from appellate panels and the Pacific Coast from the Midwest. Some of Trump’s judicial appointees have broken sharply with their colleagues on the matter, including on the 9th Circuit. Miller and Bennett appear at odds with Ryan D. Nelson and Bridget S. Bade, who expanded on the court’s June ruling in a decision Monday that allowed federalized troops to deploy in Oregon.

Most agreethat the statute itself is esoteric, vague and untested. Unlike the Insurrection Act, which generations of presidents have used to quell spasms of violent domestic unrest, the law Trump invoked has almost no historical footprint, and little precedent to define it.

“It’s only been used once in the history of our country since it was enacted 122 years ago,” California Solicitor General Samuel Harbourt told the court Wednesday.

Attorneys from both sides have turned to legal dictionaries to define the word “rebellion” in their favor, because the statute itself offers no clues.

“Defendants have not put forward a credible understanding of the term ‘rebellion’ in this litigation,” Harbourt told the panel Wednesday. “We’re continuing to see defendants rely on this interpretation across the country and we’re concerned that the breadth of the definition the government has relied on … includes any form of resistance.”

The wiggle room has left courts to lock horns over the most basic facts before them — including whether what the president claims must be provably true.

In the Oregon case, U.S. District Judge Karin Immergut of Portland, another Trump appointee, called the president’s assertions about a rebellion there “untethered to the facts.”

But a separate 9th Circuit panel overruled her, finding the law “does not limit the facts and circumstances that the President may consider” when deciding whether to use soldiers domestically.

“The President has the authority to identify and weigh the relevant facts,” the court wrote in its Monday decision.

Nelson went further, calling the president’s decision “absolute.”

Upon further review, Sung signaled a shift to the opposite interpretation.

“The court says when the statute gives a discretionary power, that is based on certain facts,” she said. “I don’t see the court saying that the underlying decision of whether the factual basis exists is inherently discretionary.”

That sounded much more like the Midwest’s 7th Circuit decision in the Chicago case, which found that nothing in the statute “makes the President the sole judge of whether these preconditions exist.”

“Political opposition is not rebellion,” the 7th Circuit judges wrote. “A protest does not become a rebellion merely because the protestors advocate for myriad legal or policy changes, are well organized, call for significant changes to the structure of the U.S. government, use civil disobedience as a form of protest, or exercise their Second Amendment right to carry firearms as the law currently allows.”

The Trump administration’s appeal of that decision is currently before the Supreme Court on the emergency docket.

But experts said even a high court ruling in that case may not dictate what can happen in California — or in New York, for that matter. Even if the justices ruled against the administration, Trump could choose to invoke the Insurrection Act or another law to justify his next moves, an option that he and other officials have repeatedly floated in recent weeks.

The administration has signaled its desire to expand on the power it already enjoys, telling the court Wednesday there was no limit to where troops could be deployed or how long they could remain in the president’s service once he had taken control of them.

“Would it be your view that no matter how much conditions on the ground changed, there would be no ability of the district court or review — in a month, six months, a year, five years — to review whether the conditions still support [deployment]?” Bennett asked.

“Yes,” Deputy Assistant Atty. Gen. Eric McArthur said.

Bennett pressed the point, asking whether under the current law the militia George Washington federalized to put down the Whiskey Rebellion of 1794 could “stay called up forever” — a position the government again affirmed.

“There’s not a word in the statute that talks about how long they can remain in federal service,” McArthur said. “The president’s determination of whether the exigency has arisen, that decision is vested in his sole and exclusive discretion.”

There you are, sitting in traffic in your car, listening to Taylor Swift on Spotify because it’s easier than subjecting yourself to a new, more challenging artist. An ad pops up in your stream. It’s serious stuff, evidenced by the dystopian tone of the narrator: “Join the mission to protect America,” the serious man’s voice commands, “with bonuses up to $50,000 and generous benefits. Apply now … and fulfill your mission.”

It’s an Immigration and Customs Enforcement recruitment ad, part of the Trump administration’s investment of $30 billion to add more than 10,000 deportation officers to its ranks by the end of the year. You would have been spared the outrage if only you had paid for Spotify’s ad-free tier of service, but there’s no way the audio streamer is getting your money now. You’ll be switching to, say, Apple Music. Maybe Tidal?

The experience of being subjected to recruitment ads for a domestic military force, assembled by a power-hungry president, has generated intense backlash that’s culminated this week in calls for boycotts of streaming services and platforms that have featured ICE spots. They include Pandora, ESPN, YouTube, Hulu and Fubo TV. Multiple HBO Max subscribers bemoaned on X that they were subjected to ICE recruitment videos while watching All Elite Wrestling: “Time to be force-fed ICE commercials against my will for two hours again #WWENXT,” @YKWrestling wrote.

Recruitment ads — Uncle Sam’s “I Want You” poster comes to mind — are an American staple, especially in times of war. But the current recruitment effort is aimed at sending forces into American cities, predicated on exaggerated claims that U.S. metro areas are under siege and in peril due to dangerous illegal immigrants, leftist protesters and out-of-control crime rates. The data, however, does not support those claims. The American Immigration Council found that from 1980 to 2022, while the immigrant share of the U.S. population more than doubled (from 6.2% to 13.9%), the total crime rate declined by over 60%.

Yet there’s a far scarier doomscape on the horizon if ICE’s recruitment efforts are successful: a mercenary army loyal only to Trump, weaponized to keep him on the throne. If that sounds more dystopian than the aforementioned Spotify ad, consider that the administration has spent more than $6.5 million over the past month on a slew of 30-second commercials aimed at luring in police officers.

The ads aired on TVs in more than a dozen cities including Chicago, Seattle and Atlanta and opened with images of each specific metro area’s skyline. Then came the commanding narration: “Attention, Miami law enforcement!” It’s followed by the same messaging that is used in ICE ads across the country: “You took an oath to protect and serve, to keep your family, your city, safe. But in sanctuary cities you’re ordered to stand down while dangerous illegals walk free — Join ICE and help us catch the worst of the worst. Drug traffickers. Gang members. Predators.”

But are the ads working? It’s hard to say since transparency isn’t a hallmark of the MAGA White House. For what it’s worth, a Sept. 16 press release from the DHS claimed that it had received more than 150,000 applications in response to its campaign and had extended 18,000 tentative job offers.

As for the power of consumer-led boycotts, there’s hope. More than 1.7 million Disney, Hulu and ESPN subscriptions were reportedly canceled between Sept. 17 and Sept. 23 during Jimmy Kimmel’s temporary suspension by ABC (Disney is ABC’s parent company). The network pulled the show after the host’s comments related to Charlie Kirk’s assassination angered MAGA supporters and the Trump-appointed FCC chair appeared to threaten the network. But after a week with a significant increase in cancellations — a 436% jump compared to a normal week — Kimmel was back on the air.

As of today, Spotify appears unmoved by the pressure to pull those intrusive ICE ads. “This advertisement is part of a broad campaign the US government is running across television, streaming, and online channels,” a Spotify spokesperson said in a statement this week. “The content does not violate our advertising policies. However, users can mark any ad with a thumbs up or thumbs down to help manage their ads preferences.”

Thumbs down. Frowny emoji. Cue the dystopian narrator for a counter ad: “Join the mission to protect America: Cancel Spotify.”

A few days ago, my 30-year-old daughter Yasmin, who has special needs, walked up to me in our little place at the school shelter. Her steps were gentle, but determined. And I could see her eyes glittering with joy. I listened intently as she was struggling to speak.

“Dad…, I ate…chocolate!” she said triumphantly.

My mind started to race, trying to work out what I had heard. Where did Yasmin get chocolate?

For many years, Yasmin has lived in a world that has its own rhythm, its own language of affection and wonder. Unfortunately, when she was just four months old, a severe fever left her with a developmental disability. And at the age of seven, she suffered chronic bronchitis and underwent lung surgery in Egypt, which further affected her health and development.

We tried to provide a comfortable life for Yasmin as much as we could. We equipped her room with a computer, a tablet, colouring books, and toys of all sorts – building blocks, teddies, balloons, and even a swing suspended from the ceiling.

We also consulted specialists who prescribed Yasmin special medication. We organised various indoor and outdoor activities for her. Hide-and-seek was her favourite game, which gave her thrills of excitement.

Fortunately, for years, we were considerably able to manage Yasmin’s condition.

However, in October 2023, an Israeli warplane attacked our beautiful house, turning it into a pile of rubble. Our belongings and resources, including Yasmin’s kingdom (her room), disappeared altogether.

Since then, we have been forcibly displaced multiple times, taking refuge in schools-turned-shelters.

Where we are staying now, Yasmin sleeps on a thin mattress in crammed conditions. There is no privacy, no quiet, no comfort.

Caring for Yasmin at the shelter has been an exhausting and draining experience. She needs help dressing, navigating the toilet queue, walking through the chaotic courtyard. We have struggled to get her even a few toys and colouring pencils. And her medications have been very hard to find.

Yasmin is a good-looking and very sociable girl. Interestingly, people don’t have much difficulty getting used to how her tongue dances differently with words. Sometimes she misbehaves, which causes annoyance. But most people show empathy towards her.

Yasmin is also very kind. She often shares her food with friends, and on different occasions, she insists on preparing gifts for them. During Eid al-Adha last year, we decorated a tray of candies, each with a note reading, “Eid is happier with Yasmin!” She distributed the gifts with pride, lighting up the gloomy atmosphere of the shelter.

Unfortunately, now the situation has only gotten worse. Israel has tightened its merciless siege on the Gaza Strip, impeding the delivery of basic food supplies, fuel, and medical and sanitation aid. The markets have seen no trace of so many things for months. No vegetables, no fruit, no meat, no fish, no chicken, no eggs, no milk, no sugar, no chocolate!

The lack of nourishment has been a serious problem for all people in Gaza. Everyone I know has grown much thinner, with pale skin and an emaciated body. My wife and I have suffered from spells of dizziness.

Yasmin has been especially vulnerable. She has lost a lot of weight, and her health has deteriorated.

In July, nearly 12,000 Palestinian children under the age of five were officially diagnosed as malnourished.

On August 22, the UN-backed Integrated Food Security Phase Classification (IPC) reported that Gaza City is officially experiencing a “man-made famine” and that an immediate, at-scale response is needed. The report marked the first time famine was declared in the Middle East.

According to the IPC, more than 500,000 people in the Gaza Strip, roughly a quarter of the population, are either close to or have already reached catastrophic levels of famine. Unless the situation on the ground changes quickly, that number is expected to rise to more than 640,000 by the end of September, while those in emergency-level food insecurity will likely rise to 1.14 million.

In addition to the casualties of the ongoing war – more than 62,000 killed and 140,000 injured – more than 315 Palestinians have already died as a result of the forced starvation, half of them children.

At this critical time, Yasmin surprisingly stood before me, carrying the lightness of a secret. With a glowing face, she declared she had eaten chocolate!

Startled, I turned to her. “You ate chocolate, Yasmin? Where? Who gave it to you?”

Sensing my confusion, she smiled and her face lit up with more delight. She gently shook her head and explained, “No, no, Dad. I…didn’t eat…chocolate. I said…I dreamed!”

I jumped up and gave Yasmin a big hug, bursting into laughter – laughter that was louder and longer than I had in months. My laughter, however, was laced with extreme sorrow and fatigue.

Amid the horrors of war and widespread famine, Yasmin had a dream of something sweet. And the dream was sweet enough to make her highly delighted.

Yasmin, a child/young woman with special needs, was not aware of the political meaning of her dream. She didn’t know that her dream, where she tasted something unreachable, was an act of rebellion against Israel’s atrocities and defiant hope to live freely in peace and dignity.

The views expressed in this article are the author’s own and do not necessarily reflect Al Jazeera’s editorial stance.

The 9th U.S. Circuit Court of Appeals decided Thursday to leave troops in Los Angeles in the hands of the Trump administration while California’s objections are litigated in federal court, finding the president had broad — though not “unreviewable” — authority to deploy the military in American cities.

“We disagree with Defendants’ primary argument that the President’s decision to federalize members of the California National Guard … is completely insulated from judicial review,” Judge Mark J. Bennett of Honolulu, a Trump appointee, wrote for the appellate panel. “Nonetheless, we are persuaded that, under longstanding precedent interpreting the statutory predecessor … our review of that decision must be highly deferential.”

Legal scholars said the decision was expected — particularly as the 9th Circuit has moved from the country’s most liberal to one of its most “balanced” since the start of Trump’s first term.

“It’s critically important for the people to understand just how much power Congress has given the president through these statutes,” said Eric Merriam, a professor of legal studies at Central Florida University and an appellate military judge.

“Judges for hundreds of years now have given extreme deference to the president in national security decisions, [including] use of the military,” the expert went on. “There is no other area of law where the president or executive gets that level of deference.”

The appellate panel sharply questioned both sides during Tuesday’s hearing, appearing to reject the federal government’s assertion that courts had no right to review the president’s actions, while also undercutting California’s claim that President Trump had overstepped his authority in sending troops to L.A. to quell a “rebellion against the authority of the United States.”

“All three judges seemed skeptical of the arguments that each party was making in its most extreme form,” said Elizabeth Goitein, senior director of the Liberty and National Security Program at New York University’s Brennan Center for Justice.

“I was impressed with the questions,” she went on. “I think they were fair questions, I think they were hard questions. I think the judges were wrestling with the right issues.”

The ruling Thursday largely returns the issue to U.S. District Judge Charles R. Breyer.

Unlike Breyer, whose temporary restraining order on June 12 would have returned control of the National Guard to California, the appellate court largely avoided the question of whether the facts on the ground in Los Angeles amounted to a “rebellion.”

Instead, the ruling focused on the limits of presidential power.

Bennett’s opinion directly refuted the argument — made by Assistant Atty. Gen. Brett Shumate in Tuesday’s hearing — that the decision to federalize National Guard troops was “unreviewable.”

“Defendants argue that this language precludes review,” the judge wrote. “[But Supreme Court precedent] does not compel us to accept the federal government’s position that the President could federalize the National Guard based on no evidence whatsoever, and that courts would be unable to review a decision that was obviously absurd or made in bad faith.”

He also quoted at length from the 1932 Supreme Court decision in Sterling vs. Constantin, writing “[t]he nature of the [president’s] power also necessarily implies that there is a permitted range of honest judgment as to the measures to be taken in meeting force with force, in suppressing violence and restoring order.”

Shumate told the judge he didn’t know the case when Bennett asked him about it early in Tuesday’s hearing.

“That is a key case in that line of cases, and the fact he was not aware of it is extraordinary,” Goitein said.

Merriam agreed — to a point.

“That’s a nightmare we have in law school — it’s a nightmare I’ve had as an appellate judge,” the scholar said.

However, “it’s actually a good thing that the attorney representing the U.S. was not planning to talk about martial law in front of the 9th Circuit,” Merriam said.

One thing Thursday’s ruling did not touch is whether the administration violated the Posse Comitatus Act by deputizing the military to act as civilian law enforcement — an allegation California leveled in its original complaint, but which Breyer effectively tabled last week.

“The Posse Comitatus Act claim has not been resolved because it was essentially not ripe last Thursday,” when troops had just arrived, Goitein said. “It is ripe now.”

“Even if the 9th Circuit agrees with the federal government on everything, we could see a ruling from the district court next week that could limit what troops can do on the ground,” she said.

In the meantime, residents of an increasingly quiet Los Angeles will have to live with the growing number of federal troops.

“[Congress] didn’t limit rebellion to specific types of facts,” Merriam said. “As much as [Angelenos] might say, ‘This is crazy! There’s not a rebellion going on in L.A. right now,’ this is where we are with the law.”