Accepted Manuscript “Political Participation as a Disability Rights Issue” Lindsey N. Kingston, Ph.D PII:
S1936-6574(14)00049-1
DOI:
10.1016/j.dhjo.2014.04.007
Reference:
DHJO 306
To appear in:
Disability and Health Journal
Received Date: 9 April 2014 Revised Date:
28 April 2014
Accepted Date: 30 April 2014
Please cite this article as: Kingston LN, “Political Participation as a Disability Rights Issue”, Disability and Health Journal (2014), doi: 10.1016/j.dhjo.2014.04.007. This is a PDF file of an unedited manuscript that has been accepted for publication. As a service to our customers we are providing this early version of the manuscript. The manuscript will undergo copyediting, typesetting, and review of the resulting proof before it is published in its final form. Please note that during the production process errors may be discovered which could affect the content, and all legal disclaimers that apply to the journal pertain.
ACCEPTED MANUSCRIPT
VIEWPOINT “Political Participation as a Disability Rights Issue” Lindsey N. Kingston, Ph.D.
Key words Voting, disability, human rights, citizenship
SC
M AN U
Corresponding author Lindsey Kingston Department of History, Politics, and International Relations 470 East Lockwood Avenue Saint Louis, MO 63119 (314) 246-8794 [email protected]
RI PT
Webster University
Word count: 1959
EP
Number of references: 8
TE D
Statements The author asserts that there are no publishable statements of funding or conflicts of interest associated with this viewpoint.
AC C
Number of figures/tables: 0
ACCEPTED MANUSCRIPT
VIEWPOINT
RI PT
“Political Participation as a Disability Rights Issue”
The fundamental right to political participation is outlined in international human rights
frameworks and United States law, yet Americans with work-preventing disabilities are persistently less likely to vote compared to the overall adult population. A variety of challenges, including mobility issues
SC
that prevent traveling to polling places, continue to hinder voter participation throughout the country.
M AN U
These obstacles threaten the government’s ability to uphold basic human rights and deny individuals with disabilities their chance to fully participate in political life. Threats to such rights also limit the functionality of citizenship, thereby weakening the relationship between the state and the individual that is essential for the protection and promotion of international human rights. Research findings by Tetsuya Matsubayashi and Michiko Ueda¹ that identify participation gaps among voters with disabilities
TE D
highlight shortcomings in existing U.S. policies, as well as vulnerabilities to rights abuses. This data illustrates the need for dialogue and policy change, using a disability rights approach to conceptualize the problem and to seek positive solutions.
EP
The human right to political participation is a basic entitlement that guarantees individuals an active role in their government. The 1948 Universal Declaration of Human Rights, which provides the
AC C
core framework for modern human rights, stipulates in Article 21 that “everyone has the right to take part in the government of his country” and that “universal and equal suffrage” is necessary for expressing the will of the people. ² Voting rights are further guaranteed by binding international law, including Article 25 of the International Covenant on Civil and Political Rights (ICCPR). Ratified by the United States in 1992, the ICCPR notes that “every citizen shall have the right and the opportunity [to vote]…without unreasonable restrictions.”³ Citizens’ voice in government is widely regarded as an
1
ACCEPTED MANUSCRIPT
essential requirement for state legitimacy; voting rights are necessary for building and maintaining governments that represent the values and needs of their constituents. Political participation has been specifically framed as a disability rights issue at the international
RI PT
and domestic levels. The Convention on the Rights of Persons with Disabilities (CRPD) protects
participation in political and public life in Article 29. The Convention asserts that governments have an obligation to “ensure that persons with disabilities can effectively and fully participate in political and
SC
public life on an equal basis with others,” which includes ensuring that voting procedures and facilities are accessible and understandable. When necessary, for instance, persons with disabilities have the
M AN U
right to request assistance in voting.⁴ Although the United States has not yet ratified the Convention (and is therefore not legally bound by it), federal legislation upholds disability rights domestically. The Americans with Disabilities Act (ADA) of 1990 prohibits discrimination on the basis of disability within state and local government activities, including voting. The Voting Accessibility for the Elderly and
TE D
Handicapped Act of 1984 requires polling places across the country to be physically accessible to people with disabilities for federal elections, or to provide an alternate means of casting a vote on Election Day. The law also requires states to make available registration and voting aids for individuals who need
EP
them in order to fully participate in political life. The National Voter Registration Act of 1993 requires state-funded offices that provide services to individuals with disabilities to provide program applicants
AC C
with voter registration forms, to assist them in completing the forms, and to transmit completed forms to the appropriate official.⁵
Despite widespread recognition of voting rights, these ideals are not always upheld in practice. In March 2012, United Nations High Commissioner for Human Rights Navi Pillay called for the removal of barriers that prevented persons with disabilities from participating in political life. She reported that recent studies conducted by her office showed that individuals with disabilities around the world continue to face legal, physical, and communication barriers to political participation. Human rights
2
ACCEPTED MANUSCRIPT
advocates contend that persons with intellectual disabilities routinely face negative stereotypes that result in their inability to vote, and related inconsistencies still exist within international frameworks – including General Comment No. 25 of the Human Rights Committee, which states that mental incapacity
RI PT
may be a ground for denying a person the right to vote or to hold office and is therefore not consistent with Article 29 of the CRPD. Individuals with disabilities continue to struggle for their right to legal capacity and decision-making, which includes accessibility of voting procedures. Shantha Rau Barriga,
SC
director of the disability rights program at Human Rights Watch, argues that “ensuring the right to political participation for persons with disabilities require[s] not only legal reform, but also a radical shift
M AN U
in our thinking about persons with disabilities – as equal citizens deserving dignity and autonomy to make their own decisions.”⁶
In the United States, the participation gap between the able-bodied and individuals with disabilities highlights challenges to fundamental rights, as well as limits on the functionality of U.S.
TE D
citizenship. Legal nationality, or citizenship, represents a form of political membership that ideally comes with government protection of human rights. For Americans with disabilities who face obstacles to voting, rights to political participation – as well their duties as members in the American political
EP
community – are threatened by inaccessibility, discrimination, and other challenges. Political theorist Elizabeth F. Cohen uses the term “semi-citizenship” to explain how citizenship exists along a spectrum⁷;
AC C
in the case of persons with disabilities, legal nationality does not guarantee full access to voting rights. Although individuals with disabilities may have U.S. citizenship, they cannot enjoy the complete range of nationality rights because they are limited from participating fully in political life. From this perspective, Americans with disabilities face obstacles to fully functioning citizenship in two key ways: First, lower voter participation rates mean that that the voices of those with disabilities are not equally represented in U.S. politics. As noted in the research study conducted by Matsubayashi and Ueda, one implication is that citizens with disabilities may be discounted in the process of producing health policy, since elected
3
ACCEPTED MANUSCRIPT
officials tend to be more responsive to those who vote in elections. Second, participation gaps suggest that going to polling places poses serious challenges to potential voters with disabilities. This implies that U.S. laws aimed at protecting the right to vote are not adequately addressing the needs of citizens
RI PT
with disabilities, which violates rights recognized at both the international and domestic levels.
For instance, research shows that many polling places are not accessible despite U.S. legislation aimed at encouraging the political participation of persons with disabilities. The U.S. Government
SC
Accountability Office (GAO) found that only 16 percent of polling places had no potential impediments to access for people with disabilities during the 2000 federal election, and that number rose to 27
M AN U
percent in 2008. Therefore, the majority of polling places were not fully accessible on Election Day. Approximately 45 percent of polling places had impediments in 2008 but offered curbside voting, meaning that the remaining 27 percent of polling places were not fully accessible and did not offer curbside voting as an option. Almost all visited polls had an accessible voting system for those who were
TE D
able to get inside the building, such as an electronic machine in a voting station. Yet 46 percent of polling places had an accessible voting system that could pose a challenge to certain voters with disabilities, such as inaccessibility to voters using wheelchairs. Thirty-one states reported that ensuring
EP
accessibility on Election Day was challenging.⁸ Although voting accessibility is improving in the United States, Americans with disabilities still face widespread challenges at polling places and cannot
AC C
adequately enjoy their right to political participation. Evidence strongly suggests that voting poses serious challenges for those with mobility and cognitive impairments, yet inclusive research and rights-based dialogue on this issue are still sorely needed. Voting gaps persist despite efforts to address the issue by federal and state governments, which highlights the existing inadequacies in policy-oriented solutions. We don’t fully understand the range of challenges that prevent voting – or the extent to which those challenges are directly tied to disabilities. That data is vital for assessing the potential impacts of proposed solutions, such as universal mail voting
4
ACCEPTED MANUSCRIPT
or electronic voting. To undertake this research, it is imperative to include the disabled community and ensure that dialogue is framed from a disability rights perspective. Civil society actors at the local, state, and international levels can provide valuable feedback related to research design, data analysis, and
RI PT
solution-seeking. Unfortunately, many policies are created without direct participation from the
minority populations they seek to impact. Research is far more likely to uncover useful data and lead to successful policy changes if persons with disabilities are included in the conversation. Furthermore, a
SC
disability rights perspective is vital because it emphasizes the importance and severity of this problem. Policies that enable voters with disabilities to participate in elections are not charity; these policies
M AN U
protect fundamental human rights and are required by legitimate governments.
More broadly, this issue uncovers wider implications for the progress of disability rights within the United States. In particular, the U.S. government’s failure to ratify the Convention on the Rights of Persons with Disabilities (CRPD) is deeply problematic for the advancement of disability rights. The
TE D
Convention not only establishes binding state responsibilities regarding political participation, but it also provides a legal framework for disability rights that includes: equality, non-discrimination, awarenessraising, accessibility, access to justice, security of person, freedom from torture and cruelty,
EP
independent living, community inclusion, mobility, respect for privacy, and rights related to work, education, and family life. Although the United States served as an international “role model” with the
AC C
passage of the Americans with Disabilities Act (ADA), its inability to ratify the Convention is troubling – particularly for a country that places the promotion of respect for human rights as “a central goal of U.S. foreign policy”⁹. The ideals outlined in the Convention should serve as a foundation for any policies related to the political participation of Americans with disabilities. The Convention provides a disability rights framework for government approaches to the participation gap, as well as related research and advocacy. It should be ratified to further protect the rights of Americans with disabilities, as well as to communicate the importance of disability rights internationally.
5
ACCEPTED MANUSCRIPT
In sum, research suggests that there is much more work to be done in order to protect the human rights of Americans with disabilities. Voting gaps between the able-bodied and individuals with disabilities highlight weaknesses in existing policies and illustrate the need for further research and
RI PT
rights-based dialogue. These inadequacies not only threaten rights and the functionality of U.S.
citizenship, they also hint at a broader failure by the government to fully acknowledge the importance of disability rights. It is imperative that stakeholders from the disability rights community are included in
SC
research, advocacy, and policy discussions – and that these activities are framed with the understanding that political participation, including voting, is a fundamental human right that must be made accessible.
M AN U
Inclusive research and dialogue are vital for advancing solutions to this issue, as well as for recognizing the necessity of disability rights protection in the United States and around the world.
REFERENCES
TE D
1. Matsubayashi, Tetsuya, and Ueda, Michiko. (2014). Disability and Voting. Disability and Health, vol/issue/pages. 2. United Nations General Assembly. (1948). Universal Declaration of Human Rights. Retrieved from http://www.un.org/en/documents/udhr/
EP
3. Office of the High Commissioner for Human Rights. (1966). International Covenant on Civil and Political Rights. Retrieved from http://www.ohchr.org/en/professionalinterest/pages/ccpr.aspx
AC C
4. United Nations Enable. (2006). Convention on the Rights of Persons with Disabilities. Retrieved from http://www.un.org/disabilities/default.asp?navid=12&pid=150 5. U.S. Department of Justice. (2009). A Guide to Disability Rights Laws. Civil Rights Division, Disability Rights Section. Retrieved from http://www.ada.gov/cguide.htm 6. Office of the High Commissioner for Human Rights. (2012). Fourth annual interactive debate of the Human Rights Council on the Rights of Persons with Disabilities: Interactive debate on participation of persons with disabilities in political and public life. Retrieved from http://www.ohchr.org/EN/Issues/Disability/Pages/politicalpubliclife.aspx 7. Cohen, Elizabeth F. (2009). Semi-Citizenship in Democratic Politics. Cambridge: Cambridge University Press.
6
ACCEPTED MANUSCRIPT
8. U.S. Government Accountability Office. (2013). Voters with Disabilities: Challenges to Voting Accessibility. Retrieved from http://www.gao.gov/products/GAO-13-538SP
AC C
EP
TE D
M AN U
SC
RI PT
9. U.S. Department of State. (n.d.). Human Rights. Retrieved from http://www.state.gov/j/drl/hr/index.htm
7
S1936-6574(14)00049-1
DOI:
10.1016/j.dhjo.2014.04.007
Reference:
DHJO 306
To appear in:
Disability and Health Journal
Received Date: 9 April 2014 Revised Date:
28 April 2014
Accepted Date: 30 April 2014
Please cite this article as: Kingston LN, “Political Participation as a Disability Rights Issue”, Disability and Health Journal (2014), doi: 10.1016/j.dhjo.2014.04.007. This is a PDF file of an unedited manuscript that has been accepted for publication. As a service to our customers we are providing this early version of the manuscript. The manuscript will undergo copyediting, typesetting, and review of the resulting proof before it is published in its final form. Please note that during the production process errors may be discovered which could affect the content, and all legal disclaimers that apply to the journal pertain.
ACCEPTED MANUSCRIPT
VIEWPOINT “Political Participation as a Disability Rights Issue” Lindsey N. Kingston, Ph.D.
Key words Voting, disability, human rights, citizenship
SC
M AN U
Corresponding author Lindsey Kingston Department of History, Politics, and International Relations 470 East Lockwood Avenue Saint Louis, MO 63119 (314) 246-8794 [email protected]
RI PT
Webster University
Word count: 1959
EP
Number of references: 8
TE D
Statements The author asserts that there are no publishable statements of funding or conflicts of interest associated with this viewpoint.
AC C
Number of figures/tables: 0
ACCEPTED MANUSCRIPT
VIEWPOINT
RI PT
“Political Participation as a Disability Rights Issue”
The fundamental right to political participation is outlined in international human rights
frameworks and United States law, yet Americans with work-preventing disabilities are persistently less likely to vote compared to the overall adult population. A variety of challenges, including mobility issues
SC
that prevent traveling to polling places, continue to hinder voter participation throughout the country.
M AN U
These obstacles threaten the government’s ability to uphold basic human rights and deny individuals with disabilities their chance to fully participate in political life. Threats to such rights also limit the functionality of citizenship, thereby weakening the relationship between the state and the individual that is essential for the protection and promotion of international human rights. Research findings by Tetsuya Matsubayashi and Michiko Ueda¹ that identify participation gaps among voters with disabilities
TE D
highlight shortcomings in existing U.S. policies, as well as vulnerabilities to rights abuses. This data illustrates the need for dialogue and policy change, using a disability rights approach to conceptualize the problem and to seek positive solutions.
EP
The human right to political participation is a basic entitlement that guarantees individuals an active role in their government. The 1948 Universal Declaration of Human Rights, which provides the
AC C
core framework for modern human rights, stipulates in Article 21 that “everyone has the right to take part in the government of his country” and that “universal and equal suffrage” is necessary for expressing the will of the people. ² Voting rights are further guaranteed by binding international law, including Article 25 of the International Covenant on Civil and Political Rights (ICCPR). Ratified by the United States in 1992, the ICCPR notes that “every citizen shall have the right and the opportunity [to vote]…without unreasonable restrictions.”³ Citizens’ voice in government is widely regarded as an
1
ACCEPTED MANUSCRIPT
essential requirement for state legitimacy; voting rights are necessary for building and maintaining governments that represent the values and needs of their constituents. Political participation has been specifically framed as a disability rights issue at the international
RI PT
and domestic levels. The Convention on the Rights of Persons with Disabilities (CRPD) protects
participation in political and public life in Article 29. The Convention asserts that governments have an obligation to “ensure that persons with disabilities can effectively and fully participate in political and
SC
public life on an equal basis with others,” which includes ensuring that voting procedures and facilities are accessible and understandable. When necessary, for instance, persons with disabilities have the
M AN U
right to request assistance in voting.⁴ Although the United States has not yet ratified the Convention (and is therefore not legally bound by it), federal legislation upholds disability rights domestically. The Americans with Disabilities Act (ADA) of 1990 prohibits discrimination on the basis of disability within state and local government activities, including voting. The Voting Accessibility for the Elderly and
TE D
Handicapped Act of 1984 requires polling places across the country to be physically accessible to people with disabilities for federal elections, or to provide an alternate means of casting a vote on Election Day. The law also requires states to make available registration and voting aids for individuals who need
EP
them in order to fully participate in political life. The National Voter Registration Act of 1993 requires state-funded offices that provide services to individuals with disabilities to provide program applicants
AC C
with voter registration forms, to assist them in completing the forms, and to transmit completed forms to the appropriate official.⁵
Despite widespread recognition of voting rights, these ideals are not always upheld in practice. In March 2012, United Nations High Commissioner for Human Rights Navi Pillay called for the removal of barriers that prevented persons with disabilities from participating in political life. She reported that recent studies conducted by her office showed that individuals with disabilities around the world continue to face legal, physical, and communication barriers to political participation. Human rights
2
ACCEPTED MANUSCRIPT
advocates contend that persons with intellectual disabilities routinely face negative stereotypes that result in their inability to vote, and related inconsistencies still exist within international frameworks – including General Comment No. 25 of the Human Rights Committee, which states that mental incapacity
RI PT
may be a ground for denying a person the right to vote or to hold office and is therefore not consistent with Article 29 of the CRPD. Individuals with disabilities continue to struggle for their right to legal capacity and decision-making, which includes accessibility of voting procedures. Shantha Rau Barriga,
SC
director of the disability rights program at Human Rights Watch, argues that “ensuring the right to political participation for persons with disabilities require[s] not only legal reform, but also a radical shift
M AN U
in our thinking about persons with disabilities – as equal citizens deserving dignity and autonomy to make their own decisions.”⁶
In the United States, the participation gap between the able-bodied and individuals with disabilities highlights challenges to fundamental rights, as well as limits on the functionality of U.S.
TE D
citizenship. Legal nationality, or citizenship, represents a form of political membership that ideally comes with government protection of human rights. For Americans with disabilities who face obstacles to voting, rights to political participation – as well their duties as members in the American political
EP
community – are threatened by inaccessibility, discrimination, and other challenges. Political theorist Elizabeth F. Cohen uses the term “semi-citizenship” to explain how citizenship exists along a spectrum⁷;
AC C
in the case of persons with disabilities, legal nationality does not guarantee full access to voting rights. Although individuals with disabilities may have U.S. citizenship, they cannot enjoy the complete range of nationality rights because they are limited from participating fully in political life. From this perspective, Americans with disabilities face obstacles to fully functioning citizenship in two key ways: First, lower voter participation rates mean that that the voices of those with disabilities are not equally represented in U.S. politics. As noted in the research study conducted by Matsubayashi and Ueda, one implication is that citizens with disabilities may be discounted in the process of producing health policy, since elected
3
ACCEPTED MANUSCRIPT
officials tend to be more responsive to those who vote in elections. Second, participation gaps suggest that going to polling places poses serious challenges to potential voters with disabilities. This implies that U.S. laws aimed at protecting the right to vote are not adequately addressing the needs of citizens
RI PT
with disabilities, which violates rights recognized at both the international and domestic levels.
For instance, research shows that many polling places are not accessible despite U.S. legislation aimed at encouraging the political participation of persons with disabilities. The U.S. Government
SC
Accountability Office (GAO) found that only 16 percent of polling places had no potential impediments to access for people with disabilities during the 2000 federal election, and that number rose to 27
M AN U
percent in 2008. Therefore, the majority of polling places were not fully accessible on Election Day. Approximately 45 percent of polling places had impediments in 2008 but offered curbside voting, meaning that the remaining 27 percent of polling places were not fully accessible and did not offer curbside voting as an option. Almost all visited polls had an accessible voting system for those who were
TE D
able to get inside the building, such as an electronic machine in a voting station. Yet 46 percent of polling places had an accessible voting system that could pose a challenge to certain voters with disabilities, such as inaccessibility to voters using wheelchairs. Thirty-one states reported that ensuring
EP
accessibility on Election Day was challenging.⁸ Although voting accessibility is improving in the United States, Americans with disabilities still face widespread challenges at polling places and cannot
AC C
adequately enjoy their right to political participation. Evidence strongly suggests that voting poses serious challenges for those with mobility and cognitive impairments, yet inclusive research and rights-based dialogue on this issue are still sorely needed. Voting gaps persist despite efforts to address the issue by federal and state governments, which highlights the existing inadequacies in policy-oriented solutions. We don’t fully understand the range of challenges that prevent voting – or the extent to which those challenges are directly tied to disabilities. That data is vital for assessing the potential impacts of proposed solutions, such as universal mail voting
4
ACCEPTED MANUSCRIPT
or electronic voting. To undertake this research, it is imperative to include the disabled community and ensure that dialogue is framed from a disability rights perspective. Civil society actors at the local, state, and international levels can provide valuable feedback related to research design, data analysis, and
RI PT
solution-seeking. Unfortunately, many policies are created without direct participation from the
minority populations they seek to impact. Research is far more likely to uncover useful data and lead to successful policy changes if persons with disabilities are included in the conversation. Furthermore, a
SC
disability rights perspective is vital because it emphasizes the importance and severity of this problem. Policies that enable voters with disabilities to participate in elections are not charity; these policies
M AN U
protect fundamental human rights and are required by legitimate governments.
More broadly, this issue uncovers wider implications for the progress of disability rights within the United States. In particular, the U.S. government’s failure to ratify the Convention on the Rights of Persons with Disabilities (CRPD) is deeply problematic for the advancement of disability rights. The
TE D
Convention not only establishes binding state responsibilities regarding political participation, but it also provides a legal framework for disability rights that includes: equality, non-discrimination, awarenessraising, accessibility, access to justice, security of person, freedom from torture and cruelty,
EP
independent living, community inclusion, mobility, respect for privacy, and rights related to work, education, and family life. Although the United States served as an international “role model” with the
AC C
passage of the Americans with Disabilities Act (ADA), its inability to ratify the Convention is troubling – particularly for a country that places the promotion of respect for human rights as “a central goal of U.S. foreign policy”⁹. The ideals outlined in the Convention should serve as a foundation for any policies related to the political participation of Americans with disabilities. The Convention provides a disability rights framework for government approaches to the participation gap, as well as related research and advocacy. It should be ratified to further protect the rights of Americans with disabilities, as well as to communicate the importance of disability rights internationally.
5
ACCEPTED MANUSCRIPT
In sum, research suggests that there is much more work to be done in order to protect the human rights of Americans with disabilities. Voting gaps between the able-bodied and individuals with disabilities highlight weaknesses in existing policies and illustrate the need for further research and
RI PT
rights-based dialogue. These inadequacies not only threaten rights and the functionality of U.S.
citizenship, they also hint at a broader failure by the government to fully acknowledge the importance of disability rights. It is imperative that stakeholders from the disability rights community are included in
SC
research, advocacy, and policy discussions – and that these activities are framed with the understanding that political participation, including voting, is a fundamental human right that must be made accessible.
M AN U
Inclusive research and dialogue are vital for advancing solutions to this issue, as well as for recognizing the necessity of disability rights protection in the United States and around the world.
REFERENCES
TE D
1. Matsubayashi, Tetsuya, and Ueda, Michiko. (2014). Disability and Voting. Disability and Health, vol/issue/pages. 2. United Nations General Assembly. (1948). Universal Declaration of Human Rights. Retrieved from http://www.un.org/en/documents/udhr/
EP
3. Office of the High Commissioner for Human Rights. (1966). International Covenant on Civil and Political Rights. Retrieved from http://www.ohchr.org/en/professionalinterest/pages/ccpr.aspx
AC C
4. United Nations Enable. (2006). Convention on the Rights of Persons with Disabilities. Retrieved from http://www.un.org/disabilities/default.asp?navid=12&pid=150 5. U.S. Department of Justice. (2009). A Guide to Disability Rights Laws. Civil Rights Division, Disability Rights Section. Retrieved from http://www.ada.gov/cguide.htm 6. Office of the High Commissioner for Human Rights. (2012). Fourth annual interactive debate of the Human Rights Council on the Rights of Persons with Disabilities: Interactive debate on participation of persons with disabilities in political and public life. Retrieved from http://www.ohchr.org/EN/Issues/Disability/Pages/politicalpubliclife.aspx 7. Cohen, Elizabeth F. (2009). Semi-Citizenship in Democratic Politics. Cambridge: Cambridge University Press.
6
ACCEPTED MANUSCRIPT
8. U.S. Government Accountability Office. (2013). Voters with Disabilities: Challenges to Voting Accessibility. Retrieved from http://www.gao.gov/products/GAO-13-538SP
AC C
EP
TE D
M AN U
SC
RI PT
9. U.S. Department of State. (n.d.). Human Rights. Retrieved from http://www.state.gov/j/drl/hr/index.htm
7
