Code word
We control what you think with Language |
Said and done |
Jargon, buzzwords, slogans |
“”…my hovercraft is full of eels!
|
—Monty Python, Dirty Hungarian Phrasebook[1] |
A code word is a type of term of art whose meaning is intentionally obscured, usually in order to increase acceptability to outsiders. The act of using code words is often referred to as dog whistle politics (see also crypto-politics), referring to the fact that the "code" can only be understood or heard by a select target group (just as a dog whistle can be heard by dogs but not by humans[2]). Many, though not all, such terms are also snarl words, used to disguise the outright offense that they would cause if the user just spoke literally. Many Christian terms, including "salvation", "pagan", and the like, were code words in the original Greek and Latin forms. Similar to the "euphemism treadmill", some code words eventually cease to be coded as they've been used so often that people can see through them.
In many respects, prayers and especially imprecatory prayers can be viewed as coded messages, although in a slightly different sense to a "code word". In these cases, prayers that call for actions — ostensibly by the hand of God — may be seen as incitement for people to actually carry it out. Prayers calling for good acts can also generate this effect, so preachers name-dropping charitable acts may inspire their flock to donate their time or money. More sinisterly, preachers who call for curses to be placed on their opponents may just be blowing off steam, but are guilty of incitement should anyone try to take the matter into their own materialistic hands — it could be further argued that this is intentional, and coding the request behind a call for divine intervention "absolves" a preacher from guilt.[note 1]
Example code words[edit]
“”Today is Wednesday.
|
—Philosophy Tube[3] |
Code words and dog whistles aim to disguise a particular view, usually in an attempt to make it palatable to outsiders who have yet to "decode" it, while allowing the less savory meanings to be understood by the in-group. This makes them slightly different from plain loaded language, which tries to sway opinions about a subject.
Specific types[edit]
Antisemitic dog whistles[edit]
“”Communism is older than Christianity. It is the curse of the ages. It hounded and persecuted the Savior during his earthly ministry, inspired his crucifixion...
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—John Rankin, totally-non-antisemitic Mississippi Congressman.[4] |
Antisemitism is often expressed in dog whistle terms, which are picked up by those familiar with the main concepts of Antisemitism but not by the populace as a whole. Examples are talk about the "controlled" media (without specifying who controls it, but anti-Semites know "who" that means); "international (often central) bankers" (without specifying Jewish international or central bankers, but anti-Semites know who);[note 2] etc. Similarly, there is the originally Stalinist denunciation of "cosmopolitanism" or "rootless cosmopolitan", and more general references to "citizens of nowhere", "international elites", etc.[5] "Dual loyalty" is a dog whistle term used by both anti-Semites and anti-Catholics to imply the person's real loyalty is to Israel or the Vatican and not their own country (demands to curtail people with "dual citizenship" are also used as an antisemitic dog whistle in a similar fashion). Another term is anti-Zionism, or criticism of Israel. While people can legitimately criticize Israel for a great many reasons, professed anti-Zionism can be a thinly-veiled front for Antisemitism. Other seemingly-innocent terms include "New York intellectual" and variations.[6]
Other antisemitic dog whistles in German language sources include bemoaning the huge influence of ("certain people"[7] on) the "East Coast [of the US]". Or more broadly, the term "Coastal elites", while it may not exclusively refer to Jews (it can also be a dog-whistle for liberals residing in coastal states), can also be invoked in reference to Jews[8][9][10] or an "Israel Lobby" that "stifles debate" or "controls the media".[11][12][13] The fact that not all people are able to "decode" dog whistles became evident in a recent court case where the question of whether calling Jürgen Elsässer a "fiery antisemite" ("glühender Antisemit" in the original German) constitutes slander.[14]
More recently, triple parentheses around a person's name has been used as a dog whistle symbol in internet forums and social media in order to single out perceived Jewish individuals for harassment.[15]
Homophobic dog whistles[edit]
For homophobes, pointing out that the opposing political candidate is "single," "never married", "a lifelong bachelor," "limp-wristed", "has no children" if they are married, or "flounced" from a debate, is a dog whistle term intended to send a signal to homophobes that others will miss. Similarly, candidates who wish to let their voters know that they are against gay rights will often say they support "family values" or "the institution of marriage".
This sort of dog-whistle talk used to be a lot more common regarding matters of sexuality in general prior to the sexual revolution, as in for example various euphemisms used in place of openly saying that a single woman was pregnant or had had an abortion.
Racist code words against African Americans[edit]
"Thug culture." Just use the n-word, we all know what you're saying anyway.[16][17] It comes off like saying black people are dumb while trying not to sound like they are saying black people are dumb. ("If only black people were smart enough to realize how dumb they really are.") Another dog whistle popular on the internet is 'dindus', short for "didn't do nothin'", which evokes the idea that black people are prone to criminal behaviour, but play up on sob stories to liberal white people.
Another way to complain about minorities without offense is to complain about ghettos, the bad part of town, "urban crime", etc. Or if one's a politician, "fixing" the impoverished areas of a city will do the trick (alternatively, "cleaning up our streets"). Particularly in the Midwest, it's common for people to mock places like Detroit, Cleveland, and the South Side of Chicago, as it sounds innocent to the untrained ear.
In addition, since the civil rights movement rendered open racism in the United States anathema (or, at least, it had), dog-whistle terms such as "community organizers"[note 3] and "welfare queen" have become widely known as semi-opaque terms referring to people (usually African-American, always underclass) who propagandists want you to believe are stirring up trouble and abusing the system. "Quotas" is a semi-opaque way of signaling opposition to affirmative action or other efforts to achieve gender or racial parity (in areas such as highest educational attainment, proportional political representation, wages, etc.) without coming right out and directly saying it. The conservative obsession with idleness and loafing used to be a dog whistle, but has become so commonplace in the Republican and Libertarian parties that people under age 40 who parrot it don't realize this.[18] They've become tone deaf to the racial overtones to the point that they don't realize it actually is racist, they just think it's a good idea.[19][20]
Particular examples[edit]
Abolition of birthright citizenship[edit]
Talk of abolishing birthright citizenship (the Fourteenth Amendment in the United States), along with other rhetoric on illegal immigration, is used to appeal to racists who are mad about brown and black people being in 'Murica at all – though this is less dog whistle and more tuba, as the paper-thin pretense is almost discarded.[21]
Alarmist[edit]
"Alarmist" is a common global warming denialist dog-whistle to refer to anyone who wants to implement policies that aim to reduce the amount of CO2 we put into the atmosphere. Referring to oneself as being a "climate realist" also qualifies. While true alarmism does indeed exist, it is extremely rare and has virtually no political influence currently.
America First[edit]
"America First" is a dog whistle for anti-immigration and xenophobic politics in the United States.[22]:70 The origins of the term date back to the anti-Catholic Know Nothings of the 1850s, but the term has recurred at various times to express bigotry and xenophobia toward different targets (by Woodrow Wilson in 1915, the KKK in the 1920s, the America First Committee of 1940-1941, and Pat Buchanan in 2000).[22]:71-81 This dog whistle was resurrected most recently by Donald Trump,[22]:69,82 The America First Congressional Caucus (Matt Gaetz, Pat Buchanan, and Paul Gosar),[22]:82-84 and Nick Fuentes' America First podcast.[22]:83-84
Anointed[edit]
"Anointed" is a dog whistle term for speaking in tongues, name it and claim it, faith healing, and other fringe practices, intended to be understood by Pentecostals but not by the general public. It is a way of saying "we believe in and practice the Pentecostal beliefs" without openly admitting it.
Balance the budget[edit]
To cut public services and aid to the vulnerable. Notably, this never involves taxing billionaires and enforcing existing tax laws on them. This predominantly-Republican/libertarian aim is beloved by undereducated people (the Right's major voter base these days) who don't understand that this would directly impact and harm them.
Biological reality[edit]
Used by various groups who claim that biological science sides with them, even if their understanding of science is oversimplified, outdated, or irrelevant to the topic at hand. Most commonly used to defend discrimination and/or justify prejudices such as sexism, racism, homophobia, transphobia, and ableism.
Cultural enrichment[edit]
This is a phrase used by white supremacists to refer to works of fiction that portray people of color, LGBT people, and women in a positive light and as a snarl word against the above-mentioned.
Ethics in games journalism[edit]
Gamergate is possibly the clearest example ever of neatly wrapping a raving bunch of toxic nuttery under a neat code phrase. Who could be against ethics?!
Family values/Pro-family[edit]
Broadly interpreted as homophobia (making many purported "family values" advocates rather "anti-family", since they are, e.g., for not allowing people to marry and start a family, if they happen to have the same plumbing as their desired spouse) and misogyny (e.g. of the "Kinder, Küche, Kirche"-kind of type or worse), but is essentially actively discriminating against most "alternative" lifestyles or anything remotely "non-traditional" (even though the supposedly-traditional, or nuclear family, of "one man, one woman, two sweet kids, a dog and a picket fence" ideal has little to no basis in historical reality).
Gender-critical[edit]
In theory, it's a term for feminism that is critical of gender roles and their impact on society. In practice, it's a code word for trans-exclusionary radical feminism, and is often used as a euphemism for that. The term evolved out of "trans-critical", which was itself an attempted response to the term "TERF".[23] But "trans-critical" is much less effective as a dog whistle, so it was largely abandoned in favor of this.
Government handout[edit]
Any money the government gives to causes you don't deem worthy. Often used by Republicans as a not-so-subtle racist dog whistle, similar to "welfare queens". Subsidies that the speaker does not oppose, like farm subsidies, veterans' benefits, or federal money transfers to money-losing "red states"[note 4] are never called "handouts", nor are the government's enormous subsidies to big business.
Health freedom/medical freedom/pro-vaccine safety/parents' right to choose[edit]
Many anti-vaccination groups and figures deny that they are "anti-vaccine" and instead hide behind more benign terms such as "pro-vaccine safety", "parents' right to choose", and "health freedom" as well as invoking Big Pharma. These tropes frequently appear when there are laws dealing with non-medical exemptions from vaccines, as these people fear government takeover and forcing children to vaccinate and giving them autism just as how the Jews were persecuted during the Holocaust.
Intelligent design[edit]
The ID movement began as a way to secularize creationism; people are happy with a "design hypothesis" but less happy when it's overtly religious. Although ID claims to be a "scientific" way of thinking, rather than just a code word, the fact that it's considered by the scientific community as identical to creationism qualifies it as a mere code word. The appearance of "cdesign proponentsists" in the "textbook" Of Pandas and People, clearly a sloppy attempt to replace "creationists" with "design proponents", is generally considered the smoking gun, though a somewhat unnecessary one given the existence of things like the Wedge Document.
Judicial activism[edit]
Any time judges make a ruling that the speaker, usually but not necessarily conservative, disapproves of. Typically, this means constitutional reasoning that the speaker finds implausible or at odds with the intent of the authors of said constitution, although in many cases the speaker has not actually read the judge's ruling.
Just label it/Right to know/Anti-GMOs[edit]
The anti-GMO movement has notably used rhetoric around "informing" people as dog whistles. "Just label it" and "right to know" are frequent rallying cries used, despite many leaders in the movement admitting that the push for GMO labelling is nothing more than a tactic for the complete elimination of the practice of genetic engineering in the food industry. A more egregious example would be the co-opting of the latter phrase by the organization US Right To Know, which is actually an organic industry front group that has been more focused on harassing scientists than giving the public valuable information.
Male-friendly content[edit]
This and similar terms have been cropping up increasingly amongst MRA forums and rants about feminists. It's basically code for rape jokes and threats about domestic violence.
Open mind/do your own research[edit]
Usually when this is used as an escape hatch, either to denigrate an opponent as supposedly "closed minded", or possibly a euphemism for "why won't you agree with me?!" — often used in conjunction with "decide for yourself", which basically means "if you don't decide the same thing as me, you need to open your mind".
Parents' rights[edit]
The use of the term "parents' rights" with regard to public schools in the United States has become a dog whistle for some parents' rights: conservative white heterosexual cis parents who don't want their children to read about comprehensive sex education, gender, or the history of non-white people. Glenn Youngkin successfully exploited this dog whistle when he ran for governor of Virginia in 2021.[24]
Patriot[edit]
Patriot is a term used by Sovereign citizens to self-identify. Apparently you can't be patriotic unless you perform the voodoo rituals that will allegedly remove yourself from Federal jurisdiction.
Physical removal[edit]
While this could mean exile or deportation, it is sometimes used by far-right extremists to mean murdering political opponents or people of other races. Fortunately, usually a fantasy among the online far right, but can sometimes be used literally, e.g. in the manifesto of the Christchurch terrorist in 2019.
Pornography[edit]
While it is sometimes used to refer to actual opposition to porn, including feminist criticism of it, rhetoric about "the evils of pornography" is often a dog whistle used by homo-, bi-, and transphobes to describe LGBT rights. It can also be used more broadly for the societal change brought about by the sexual revolution, including abortion, comprehensive sex education, contraception, non-procreative sex, and sex-positivity. Both variants seek to incite a moral panic about the permissive society, and are often combined with "protecting the children".
When anti-porn is used as a code word, books acknowledging that gay and trans people exist is equated with providing hardcore porn to children, women who refuse to conform to traditional gender roles or are open about enjoying sex are labeled as "sluts", trans people living openly is denounced as gender ideology, and anyone offering information about contraception or help to survivors of sexual violence is lumped in with sex criminals. The anti-LGBT variant of this features in Project 2025, which calls for "pornography" to be banned and "pornographers" to be jailed. From the foreword to their manifesto:[25]
Pornography, manifested today in the omnipresent propagation of transgender ideology … is as addictive as any illicit drug and as psychologically destructive as any crime. Pornography should be outlawed. The people who produce and distribute it should be imprisoned. Educators and public librarians who purvey it should be classed as registered sex offenders. And telecommunications and technology firms that facilitate its spread should be shuttered.
Preemptive strike[edit]
Refers to an unprovoked attack, made to sound like it is more justified.
Pro-choice/pro-life/Dred Scott Decision[edit]
These can mean a number of different things depending on who says it, but in general, bringing up the idea of "choice" is used to demonize an opponent as "anti-choice", and by extension "anti-freedom". For example, pro-choice leads to the idea that anti-abortion campaigners are against a woman's right to control their fertility, and choice is also brought up by anti-vaxxers when they know that their claims can't be backed up by evidence — they must be given a choice of whether to take a vaccine ("health freedom" or "medical freedom"), and evidence and benefits are irrelevant. Similarly, "pro-life" is used to insinuate that proponents of legalized abortion not only approve of abortion, but approve of death and killing as well.
Another example is when pro-life activists talk about the "Dred Scott Decision". Among them, Roe v. Wade is analogous to Dred Scott v. Sandford, in that it keeps fetuses from having any rights. However, since Roe v. Wade is popular, and Dred Scott is not, a politician (or potential Supreme Court Justice) can talk about Dred Scott when they are really talking about Roe v. Wade.
Radical Islam[edit]
Roughly translates in reality as all of Islam, radical or otherwise. "Combating radical Islam" is usually used in place of "let's invade their countries and convert them to Christianity", or worse, "Nuke Mecca". The misuse of this term has, unfortunately, made it difficult for those who wish to combat only radical or fundamentalist Islam (read: people with an actual functional moral code).
Recognize the enemy[edit]
Using profiling to weed out who a terrorist is, i.e., do they look Muslim? Essentially code for "Round up the ragheads."
Religious freedom/religious liberty[edit]
The "freedom" to continue withholding basic rights from the LGBTQ community or anyone else whose existence one feels offended by. Not to be confused with freedom of religion (though the people using this code word hope you'll make that mistake).
Right to work (or recently, the even more Orwellian "economic freedom")[edit]
Used to put a warm, fuzzy glow on policies aimed at busting unions and obliterating workplace safety and employee rights. These are particularly nasty examples, as they're carefully crafted to appeal to the people they hurt most, like unemployed and under-employed blue-collar workers. The upshot of such laws is often to create or exacerbate a negative externality, wherein the owners gain greater profit at the workers' expense.[26]
Secure the border[edit]
In a similar vein to 'right to work', a euphemism used in the U.S. for securing the Mexican border so as to keep out "racial undesirables"; the Canadian border is never mentioned (or extremely rarely and only during diatribes about the northern neighbor of the US being supposedly Communist, Liberal, or what-not).
Strong national defense[edit]
Often used by, e.g., neoconservatives as a euphemism for "bombing the shit out of uppity foreign countries", since neocons pretend to be doing this in furtherance of human rights and cannot say that openly. It also refers to increasing military spending, often exponentially.
School choice[edit]
Getting around desegregation, while also making sure little Billy or little Suzy don't learn science or history in school and grows up to be a good stupid little conservative.
States' rights[edit]
This is the granddaddy of modern-day American dog whistles, growing out of racist opposition to the Supreme Court decision on Brown v. Board of Education, and eventually spawned the Republican Southern Strategy (and thus the ruination of any claim to actual morality the Republican Party could possibly hold). The best known example of this is the love some older conservatives have for "states' rights". When segregation became socially unacceptable, many old pro-segregationists began instead calling for "states' rights", meaning of course the right of the individual states to segregate and discriminate (or, in the pre-Civil War American South, enforce slavery). Since then, many civil rights leaders have been able to show the connections behind the phrase, but that doesn't stop hard-right Ron/Rand Paul supporters from continuing to use it. These days, it's used by people in red states to justify tighter immigration law (i.e. racial profiling) and toying with Roe v. Wade by restricting abortions. Interestingly enough, even the most fervent states' rights apologists become eerily silent when it comes to Colorado legalizing pot or (in the 1990s and early 2000s) gay marriage. Which of course parallels what the Antebellum South did: As long as they had the political power to do so, the states' rights of the Northern states did not concern them when it came to enforcing "fugitive slave" laws that often ended up enslaving free black Northerners.[note 5]
Terrorist[edit]
Used by every bad government ever to defend some kind of likely bad action that they've done. If it's a war, the government will call its (usually non-state) opponents terrorists, regardless of how moderate they are or whether they target civilians. See Syria, Saudi Arabia, Turkey, and the Uighur genocide for prime examples.
Tough on crime[edit]
"Three strikes" laws, rounding up all those uppity negroes non-violent drug offenders, and generally everything that has led to the high rate of incarceration in the US, all the while sending profits to private prisons. Using capital punishment despite overwhelming evidence that it doesn't actually work as a crime deterrent.
Voter fraud[edit]
"Voter fraud" is often used by Republicans to refer to darkies minority voters, who predominately vote Democratic, to give justification for laws that make it harder for those voters to vote. Since actual voter fraud is incredibly rare in the United States (less than one-one thousandth of one percent of all votes cast, and most of it actually favors Republicans), it's rather obvious what this term really means when a Republican uses it.[note 6]
See also[edit]
- Alt-right glossary — much of their language is used to conceal their actual meanings as a form of bait-and-switch
- Euphemism
- Loaded language
- TERF glossary — similarly to the alt-right, TERFs use a variety of code words to hide their true intentions from unsuspecting readers
- Weasel word — not quite the same thing, but similar in purpose in obfuscating the true content of a speech or argument in order to facilitate undeserved acceptance[note 7]
External links[edit]
Notes[edit]
- ↑ Whether a judge or jury would actually accept this excuse may vary.
- ↑ This can even be a tad more direct if the names of certain banks are emphasized in an odd way; Lehman, for example, is a common German name, but mentioning the name in a certain way is bound to be "understood" by those "in the know".
- ↑ Thank you so very, very much, Sarah Palin, for letting us know what a sociopath you are.
- ↑ Almost all "red states" are net takers of federal money, whereas noted liberal bastions like New York and California pay way more money to DC than they get back.
- ↑ Have we pointed out that right-wingers are evil often enough yet? Because they're evil.
- ↑ Basically "we will do literally anything, no matter how immoral and depraved, to seize and hold political power so we can use it to gain all the money and destroy everyone who isn't us". Did we mention that Republicans are evil?
- ↑ Weasel words grant illusionary strength to a weak argument, whereas code words grant illusionary respectability to a repugnant argument.
References[edit]
- ↑ Monty Python's Flying Circus - Dirty Hungarian Phrasebook at YouTube.
- ↑ Blue Sky Science: How can dogs hear a dog whistle but people cannot? Wisconsin State Journal.
- ↑ The Philosophy of Antifa, Youtube.
- ↑ https://www.sun-sentinel.com/opinion/fl-xpm-2010-03-09-fl-jjps-warshal-0310-20100309-story.html
- ↑ The anti-semitic origins of “citizens of nowhere”., Politics Means Politics, Jun 8, 2018
- ↑ Stanley Kubrick: New York Intellectual, UK Research and Innovation
- ↑ https://books.google.de/books?id=9XgsCQAAQBAJ&pg=PA146&lpg=PA146&dq=gewisse+Kreise+an+der+Ostk%C3%BCste&source=bl&ots=_6odj0ZiLb&sig=d5Hai8nkYbJMsjNxoowgFbsA-Xc&hl=de&sa=X&ved=0CDsQ6AEwBmoVChMIofPS4ajFxwIVy9QaCh1ERA_D#v=onepage&q=gewisse%20Kreise%20an%20der%20Ostk%C3%BCste&f=false
- ↑ http://www.zeit.de/2007/26/Waldheim
- ↑ https://books.google.de/books?id=FyqdBgAAQBAJ&pg=PA299&lpg=PA299&dq=gewisse+Kreise+an+der+Ostk%C3%BCste&source=bl&ots=uIo3MDhZoW&sig=4JhFVA13yqwhx9Mc_hF8de8jmgY&hl=de&sa=X&ved=0CCwQ6AEwA2oVChMIofPS4ajFxwIVy9QaCh1ERA_D#v=onepage&q=gewisse%20Kreise%20an%20der%20Ostk%C3%BCste&f=false
- ↑ http://www.tagesspiegel.de/politik/bei-waldheim-reagierte-oesterreich-trotzig-bei-haider-kann-auslaendische-kritik-helfen-kommentar/118940.html
- ↑ https://books.google.de/books?id=9XgsCQAAQBAJ&pg=PA146&lpg=PA146&dq=gewisse+Kreise+an+der+Ostk%C3%BCste&source=bl&ots=_6odj0ZiLb&sig=d5Hai8nkYbJMsjNxoowgFbsA-Xc&hl=de&sa=X&ved=0CDsQ6AEwBmoVChMIofPS4ajFxwIVy9QaCh1ERA_D#v=onepage&q=gewisse%20Kreise%20an%20der%20Ostk%C3%BCste&f=false
- ↑ https://books.google.de/books?id=9XgsCQAAQBAJ&pg=PA146&lpg=PA146&dq=gewisse+Kreise+an+der+Ostk%C3%BCste&source=bl&ots=_6odj0ZiLb&sig=d5Hai8nkYbJMsjNxoowgFbsA-Xc&hl=de&sa=X&ved=0CDsQ6AEwBmoVChMIofPS4ajFxwIVy9QaCh1ERA_D#v=onepage&q=gewisse%20Kreise%20an%20der%20Ostk%C3%BCste&f=false
- ↑ Tanya Cariina Hsu, "How the Isreali Lobby Works in the United States", GlobalResearch.
- ↑ Benjamin Weinthal (10/17/2014). "German judge sparks outrage, says anti-Semitism was only limited to Nazi period". The Jerusalem Post.
- ↑ Fleishman, Cooper; Smith, Anthony (1 June 2016). "(((Echoes))), Exposed: The Secret Symbol Neo-Nazis Use to Target Jews Online". Mic. Retrieved 4 June 2016.
- ↑ Gabrielle Bluestone, [Gawker.com: archive.is, web.archive.org "Just Call Them Niggers"]
- ↑ Anthony Cumia Twitter rant
- ↑ Ian Haney López, "Dog Whistle Politics" at TEDxUOregon".
- ↑ Courtland Milloy, "Charles Murray and shiftless, lazy whites", Washington Post.
- ↑ Gary Anderson, "Peter Schiff: More Racist Economics From A Libertarian", Business Insider. ("It is a scam because fostering racism is racism. If you set up racist policies you are fostering racism. Most normal people understand that, but Libertarians are far from normal.")
- ↑ Patrick Howell O'Neill, "Donald Trump is winning over the white supremacist vote"
- ↑ 22.0 22.1 22.2 22.3 22.4 "America First" by Sarah Churchwell. In: Myth America: Historians Take On the Biggest Legends and Lies About Our Past, edited by Kevin M. Kruse & Julian E. Zelizer (2022) Basic Books. ISBN 1541601394. Pages 69-84.
- ↑ Hannah McCann and Lucy Nicholas (February 18, 2019). "Gender troubles". Inside Story.
- ↑ Democrats fight back as Republicans target education in push for suburbs by Stephen Collinson (6:38 AM EDT, Wed October 27, 2021) CNN.
- ↑ [1]
- ↑ Rights In Common: A Deconstruction Of Political Speech, Agency Fee Structures, And The Union As Commons After Janus v. Fee Structures, And The Union As Commons After Janus v. AFSCME AFSCME by Susannah Maltz (2018) City University of New York Law Review 21(2):285-325.