The relationship of Jews and Jewish identity to the surrounding non-Jewish society is one of the drivers that shapes Jewish identity in the Diaspora, in a number of ways. Liberal, Non-Orthodox and Modern Orthodox Jews have in part shaped the parameters of their values and identity to facilitate their integration into non-Jewish society or a strategy to accommodate to a non-Jewish culture. This effort has intensified in America in the light of the significant impact that Jewish culture has had on the general American general culture. Indeed, one of most significant catalysts of the acceptance of Jews and and their place of the Jews in America is the fact that American values and culture have Judeo-Christian underpinnings. The Puritans saw themselves as latter day Hebrews, and a serious proposals were made to make Hebrew the official language of the new nation (first in 1620 by William Bradford and then again in 1780 in the midst of the Revolutionary War). In Harvard College orations were delivered in Hebrew, starting in 1642 at the first commencement ceremony until the end of the eighteenth century. It would seem that over the years it was the humanist values embedded in the Jewish tradition that had the most impact in shaping America’s Judeo-Christian heritage over the years. The recognition that America enjoyed a Judeo-Christian humanist heritage facilitated the influence of such Supreme Court justices as Louis Brandeis and Felix Frankfurter and the adoption of Biblical verses on central American symbols such as the Statue of Liberty (“Proclaim Liberty throughout all the Land” – Lev. 25:10).
Conversely, in reaction to the attractions of non-Jewish society, some traditional and Orthodox Jews have raised and hardened the boundaries of their Jewish identity, and even non-Orthodox and Reform have become more explicitly and boldly Jewish.
This year’s Annual Assessment examines this dimension of Jewish identity in relation to the recent election in the United States. The 2016 election cast light on increased political and cultural polarization between Orthodox and liberal elements in the American Jewish community. This chapter describes this polarization vis-a-vis voting patterns, political party affiliations, and social and political views. In addition, it discusses visible connections between the Orthodox Jewish community with the Trump administration and the contrasting, sometimes vociferous opposition to the administration and its policies by some liberal Jews and rabbis. Finally, it argues that these different political orientations appear to be connected to two alternative implicit strategies, one liberal and one conservative-Orthodox, of Jewish integration into American life.
American Jewish Voting Patterns in the 2016 Election
The American Jewish vote in the presidential election was bifurcated. According to exit polls, approximately 70 percent of U.S. Jews voted for Clinton and 25 percent voted for Trump (the remaining 5 percent voted for Gary Johnson or Jill Stein). Behind these overall numbers lies a significant difference in pattern between Orthodox and non-Orthodox Jews. Exit polls showed that over 70 percent of Reform and Conservative Jews voted for Clinton (76 and 71 percent respectively).1 Among the Orthodox, the number was lower, only 56 percent supported Clinton. Thirty-nine percent of Orthodox Jews supported Trump, as opposed to 21 and 25 percent respectively among Reform and Conservative Jews. If one looks at real voting results in neighborhoods with large concentrations of Modern Orthodox and Haredi Jews (which some writers claim is more accurate than exit polls), the result is even more dramatic. In five Modern Orthodox neighborhoods in Greater New York, Chicago, and Florida, Trump received between 45 and 90 percent of the vote, and in Haredi neighborhoods in Brooklyn, New Jersey, and Ohio, he received between 56 and 94 percent.2 It must be borne in mind that, as of now, the Orthodox are about 10 percent of the Jewish population and the non-Orthodox 90 percent.
This shift to support for Republican candidates on the part of the Orthodox is not a one-time “blip.” It represents a consistent voting pattern in the four presidential elections since 2004. In fact, in many places Trump received fewer Orthodox votes than either Romney or McCain had. Furthermore, according to the 2013 Pew survey of American Jews, over 55 percent of Orthodox Jews say that they lean Republican. This shift to Republican support is not arbitrary; both Modern Orthodox and Haredi Jews exhibit more conservative political attitudes that non- Orthodox Jews. A much larger percentage of Orthodox Jews disapproved of President Obama (over 50 percent) than other Jews (29 percent), and a majority of Orthodox Jews favor smaller government.3
Liberal Jewish Opposition to the Trump Administration
If we look to the other side of the spectrum, as we have indicated, 70 percent of the Jewish community voted for Clinton. Moreover, the more liberal a community is religiously, the more it voted liberal politically. Seventy-six percent of Reform Jews, cast their votes for Clinton.4 Furthermore, many non-orthodox younger Jews voted for and supported Bernie Sanders in the Democratic primaries. Again, the liberal nature of the Jewish electorate represents a long-standing trend. The majority of Jews have consistently voted liberal, left or Democratic since the start of the 20th century.5 Furthermore, the 2013 Pew report declared that “Jews are among the most liberal, Democratic groups in the population.” It is noteworthy, though, that within this pattern, the less that one is religious or emphasizes particularistic Jewish identity and attachment, the more liberal are one’s social and political attitudes. Thus, while 70 percent of all U.S. Jews are Democrats or lean Democrat, among Jews of No Religion, Reform Jews and Jews of No Denomination the percentages are 78, 76, and 75 respectively. Similarly, 82 percent of all Jews said that homosexuality should be accepted by society, but percentages were recognizably higher for Reform Jews (92 percent), Jews of No Denomination (89 percent), and Jews of No Religion (91 percent). Insofar as millennials have high representation among Jews of No Religion, these very liberal views probably characterize many of them as well.
This liberal attitude also expresses itself in literature among younger writers who started publishing in the new millennium. This liberal approach has especially expressed itself in criticism of what is perceived as the mainstream Jewish community and “mainstream Jewish values.” In the titular story in Nathan Englander’s 2012 short story collection, What We Talk About When We Talk About Anne Frank, the centrality of the Holocaust and its symbols in American Jewish identity is examined and even to a certain extent lampooned. In a somewhat similar vein, Jonathan Safran Foer’s 2017 novel, Here I Am, considers American Jewish objections to, and demurral from, the perceived roughness and brutality of Israelis. This novel looks at the trajectory of American Jewish solidarity with Israel and how it has evolved into a relationship characterized by increasing complexity and ambivalence. These works join Michael Chabon’s The Yiddish Policeman’s Union in its critique of religious Zionist Messianism, right-wing Israeli government policy and Christian right-wing movements in America.
Thus, the current crop of young Jewish writing, continues the tradition of American Jewish liberalism and social critique but with a tone that is somewhat more far-reaching and critical than previous writing especially as concerns Israel. This tone seems to be in accord with the current polarization in American politics between liberal and conservative/populist camps. One central expression of this polarization was the 2016 election and its aftermath. Not only was the campaign extremely acrimonious, but the acrimony continued after the election results were announced. One of the main expressions of this continuing conflict was the prominence of street demonstrations protesting the Trump administration and its policies.6 Many Jews have participated in these as individual citizens of the United States. However, beyond this, many Jews and Jewish organizations have participated in these demonstrations as Jews and on the basis of their Jewish identity. One such issue was the Trump administration’s effort to ban U.S. entry by citizens from seven predominantly Muslim countries. The three major Jewish religious denominations issued statements protesting the ban, with the Reform statement being the harshest rebuke: “The Reform movement denounces in the strongest terms the horrifying executive order on immigration and refugees,” it said. Even more pointedly, 20 rabbis, affiliated with the liberal movements, some wearing talitot (prayer-shawls), protested the ban, and were arrested for obstructing traffic on Columbus Circle in New York. The protest was organized by T’ruah: The Rabbinic Call for Human Rights, a non-profit group whose mission is to “bring together rabbis and cantors from all streams of Judaism, together with all members of the Jewish community, to act on the Jewish imperative to respect and advance the human rights of all people.”7 “We remember our history, and we remember that the borders of this country closed to us in 1924 with very catastrophic consequences during the Holocaust,” Rabbi Jill Jacobs of T’ruah said. “We know that some of the language that’s being used now to stop Muslims from coming in is the same language that was used to stop Jewish refugees from coming.”8
While most leaders of Reform, Conservative and other Liberal groups deeply believe that their liberal perspectives on social issues emerge from their deeply held Jewish values, many observers believe that there is a strong tendency among some liberal groups to conflate Liberal and progressive values with Jewish values. Thus, Rabbi Dara Frimmer, in 2009, characterized the attitude of her young age cohort as follows: “Don’t keep kosher, that’s fine, don’t keep Shabbat, that’s fine, marry a non-Jew – whatever. But understand that it will take away your Jewish identity if you don’t fight for justice.”9 In a similar vein, in September 2016, a Jerusalem Post op-ed opposing the Trump immigration policy on Jewish grounds bore the title: “Jewish Values are to Welcome Strangers, Something Trump Doesn’t Stand For.”10
It is practically certain that these developments were influenced by the polarization in the politics and culture of the general American society that found significant expression in the last presidential election. The religious, values related, cultural, and economic concerns of the central swath of the population that is white, religious (Evangelical or Catholic) and working or lower middle class found strong expression in the victory of Donald Trump. To a large extent, Orthodox Jews share these concerns.
Different Implicit Strategies of Integration into American Society
Underlying these differences between the Orthodox and liberal groups seems to be the growing crystallization of two different strategies of Jewish integration into general American society and identity. The first, liberal Jewish strategy is the classic model Jews in the West have adopted since the end of the 18th century. The liberalism of the majority of the Jewish community and their tendency to conflate liberal values with Jewish values is not simply the subjective preference of individual Jews. Rather, it seems to be related to the historical position of the Jews as a minority and the strategy that the Jews crystallized over the last 200 years for integration into the non-Jewish societies in which they lived. This classic strategy, which had been in use since the Enlightenment and the Emancipation, involves the adoption of the liberal civic virtues of tolerance, pluralism, civil and human rights, civic equality etc. and the minimizing of cultural and religious characteristics that mark the Jews as different from the general population. In the American case, it prefers that American national identity be based upon the American civil creed (“dedicated to the proposition that all men are created equal”) without too much emphasis on the Christian or Anglo-Saxon ethnic or cultural bases for American identity.11 To this very day, liberal Jews are one of the most vigilant groups with respect to the separation of church and state in the United States.
All Jews commonly understood the nature of the “deal” that modern Western society offered them in the framework of this strategy: In exchange for less explicitly expressed Jewish identity, they could achieve enhanced integration and achievement in the surrounding non-Jewish society. Jewish groups differed as to the extent that they would accept the deal. Many Jews shed their particular cultural and religious characteristics and, indeed, achieved outstanding integration and achievement in Western societies. Other (Orthodox and Ultra-Orthodox) groups retained more particularist characteristics, and as a group, attained less integration.
Today with the rising prominence of Orthodox Jews in the Trump administration and in certain business, real estate and legal circles we may be witnessing the rise of an alternative strategy of Jewish integration and an alternative “deal.” This strategy would likely entail alliances with other, non-Jewish religious and conservative groups based upon a shared moral culture which is religiously based.
Like the original deal, the emerging alternative strategy comprises several levels. In what follows we parse these levels and compare the liberal strategy of Jewish integration with the emerging conservative one. According to the classic strategy, the Jews expected that they would become part of a “neutral” or “semi-neutral” society,12 that is, a general society, or at least a public sphere in which religious and ethnic identities would not be present or, at least, prominent. Religious and ethnic identities would be relegated to the private sphere, if they existed at all. They similarly expected or hoped, that non-Jews would be likeminded liberals, committed to the values of equality, tolerance, pluralism etc., and would share, at least in the public sphere, a common, secular, liberal identity.
In the last decades of the twentieth century and the first decades of the the twenty first, some of the groups which had been associated with this liberal strategy such as reform, conservative and even modern Orthodox groups underwent a change. Under the impact of the multi-cultural celebration of different ethnic and cultural groups, which started with “black is beautiful”, these groups have given more emphasis to explicit Jewish religious symbols such as publicly marking Jewish holidays and making their services less “Protestant” and more Jewish (more use of Hebrew, talitot etc.).
It may be suggested that some Orthodox groups are going beyond this and developing an alternative strategy. In contrast to the liberal strategy, the Orthodox, conservative strategy builds upon alliances with other, non-Jewish religious groups, built, at the first level, upon shared interests. These would include increased government funding of religious education and the exemption of religious organizations, individuals and communities from the imposition of progressive mores (such as same sex marriage and the free availability of abortion) by force of law.13 Furthermore, Orthodox groups wish to ally themselves with other non-Jewish religious, conservative groups because of the pronounced pro-Israel orientation of these groups. Not only are these groups pro-Israel in a general way, but they also support Jewish right wing and religious policies in regard to the settlement and incorporation of the Greater Land of Israel. Beyond the question of shared interests, there might also be a level of shared moral culture and shared identity.14
This brings us to the next two levels of the respective integration strategies. As indicated above, the liberal strategy of Jewish integration prefers that American national identity be based upon the American civil creed. without too much emphasis on the Christian or Anglo-Saxon ethnic or cultural bases for American identity. In contrast, the conservative-Orthodox strategy seems to accept the general conservative position (articulated, for example, by Samuel Huntington15) that American national identity is not only narrowly based upon Civil Creed but also upon a shared moral culture, which rests upon a religious (Protestant/Christian or Judeo-Christian) culture.16 This moral culture which Jewish conservatives (especially Orthodox religious conservatives) share with non-Jewish, especially Christian conservatives seems to rest upon different assumptions than liberal morality. This is the final level or aspect of the respective integration strategies we will compare.
The social psychological research of Richard Shweder and especially Jonathan Haidt points to the fact that different cultures and population groups have different underlying conceptions and approaches to morality. Haidt talks about two main approaches: a “contractual approach” and a “beehive approach.” “The contractual approach takes the individual as the fundamental unit of value. The fundamental problem of social life is that individuals often hurt each other and so we create implicit social contracts and explicit laws to foster a fair, free, and safe society in which individuals can pursue their interests and develop themselves and their relationships as they choose.”23 The rules the contractual approach develops largely focus upon not harming other people and caring for them, especially the helpless and the oppressed. They also value fairness and reciprocity.
“The beehive approach, in contrast, takes the group and its territory as fundamental sources of value. Individual bees are born and die by the thousands, but the hive lives for a long time, and each individual has a role to play in fostering its success. The two fundamental problems of social life are attacks from outside and subversion from within. Either one can lead to the death of the hive, so all must pull together, do their duty, and be willing to make sacrifices for the group.”18 The beehive approach will propound within its system of moral rules and values, as we shall see, other issues beyond harm/care and fairness/reciprocity.
Liberals consider the individual the regnant unit of value. Hence, their moral assumptions are mainly “contractual.” Conservative and traditional groups tend to view the group as the regnant unit of value. Hence, While liberals tend to think that something is morally wrong only if it harms or oppresses other people, according to the research of Jonathan Haidt and other social psychologists, conservatives and traditional people in general have a larger list of moral concepts and understand key notions somewhat differently.19 They tend, as well, to emphasize as moral values norms and behaviors that promote the survival and well-being of the group.
In addition to the virtue of care (for small children and helpless animals and by extension for all unfortunates) and liberty from oppression that they share with the liberals,20 Conservative moral concepts also include:
- Fairness as proportionality –. i.e. people should get their just desserts, or as St. Paul put it “he who does not work neither shall he eat.” People who work and contribute deserve their benefits. Freeloading is a moral sin. Hence they tend to question whether the recipients of welfare or government benefits actually deserve them.21 Liberals, in contrast, think of fariness in terms of privileged people taking advantage of non-privileged groups. Hence they insist that wealthy people should pay their fair share of taxes or that dis-privileged people should get higher, that is fairer, benefits that provide minimum income, shelter, health etc.22
- Loyalty – One should support and contribute to the immediate groups that one belongs to: family, community, nation and country. Dante put the betrayers in the lowest circle in the Inferno. Conservatives are more comfortable being part of a group than liberals are and will tend to enforce group loyalty even if it comes at great cost to individuals.
- Sanctity – There is a “higher” side to man’s nature and one’s body should be treated as a temple not as an amusement park. Normatively speaking, one’s bodily and sexual behavior is not entirely determined by oneself as an autonomous individual.
- Authority – Human beings like other animals are organized into hierarchies that are not by definition oppressive – i.e. parents and children, clergy and laymen.23 Conservatives and religious traditionalists will demand respect and obedience for authority even if it is not entirely rationally justified, such as authority that is age and gender based.
Because of their individualistic orientation, liberals tend to think of morality in universalistic terms. The idea that one should give preferential treatment to members of one’s ethnic or religious group (or even one’s family) is embarrassing to certain liberals.24 None of the above arguments should be taken to imply that liberals are not loyal or disrespectful to authority However, they tend to give these concepts a more individualistic and rational interpretation.
Of course, from a liberal point of view, much of conservative and traditional morality smacks of irrational adherence to tradition and superstition, and values such as group loyalty at the expense of individual fulfillment, blind obedience to authority, and traditional restrictions on human sexual behavior and orientation often seem to be immoral suppressions of human autonomy and interpersonal oppression.
Orthodox Jews who believe in reward and punishment (and who think of themselves as deserving middle class people); who believe in unquestioning loyality to their families, communities and people (Am Yisrael) and (despite traditional Jewish reserve towards Gentile governments) are developing a form of right-wing patriotism towards their nation (America);25 who respect the authority of parents and of rabbis and who try and live their lives in accordance with Kedusha (sanctity) seem to share this moral culture. Through their membership in this shared moral culture, they claim membership in American society and American identity. It is important to emphasize that according to this strategy, they claim their American membership not despite their Orthodoxy (as liberal Jews believe), but because of it. Their Orthodoxy makes them part of the moral culture – which they share with evangelical Protestants and (white) believing Catholics – which, in the eyes of these groups, grounds American democracy. In other words, they seem to be proposing a new deal: Become American by emphasizing your Orthodox way of life and the values that this embodies.
American identity according to this Orthodox approach is achieved upon a higher level of abstraction. Jews, Evangelicals and (white, devout) Catholics share the same moral/religious culture and the same moral values. However, they actualize these values in parallel fashion in their respective faith traditions and communities. A certain reservation is in order here. In the context of the “new deal”, Haredi and especially Hassidic Jews, having much less secular education, command of English and income than the American Jewish norm, might not achieve the same level and quality of influence on the general society that Jews today enjoy. Nevertheless, Haredi and Hassidic groups have proven over the years to be enormously resourceful and resilient and they might find other, new channels for maintaining access to power centers of American life and influence upon them. In fact, in recent years Haredi and even Hassidic groups have established policy research institutes and consulting firms.
If there really are two strategies for Jewish integration into American society, then that implies a deep difference between the Orthodox and the liberal streams of the American Jewish community. Until around
2000 it was reasonable to assume that Orthodox and liberal Jews had similar interests and aspirations vis-a-vis American society. The differences between them had to do with the lengths that each community was willing to go in order to achieve them and the manner in which each accordingly approached the Jewish tradition. If each community, though, is developing different or even opposing aspirations vis-a-vis American society and their place within it, that represents a new level of dissent and even polarization with the community.
As we have written in previous Annual Assessments, the Orthodox community in the United States is strengthening demographically. This demographic strength is translating, unsurprisingly into political strength. For the most part, the Orthodox and especially the Ultra-Orthodox utilize their political power to obtain benefits for their own communities., including state support for religious education and the exemption of religious organizations, individuals and communities from the imposition of progressive mores by force of law. To a certain extent its also seems to include the promotion of a socially conservative agenda for general American society.26 In pursuit of these goals they are forming alliances with similar religiously conservative groups such as Evangelicals and devout Catholics. At the same time, the ultra-Orthodox especially, are not much engaged with the general organized Jewish community and, as we have seen, they are a lot less involved with general American life and their ability to influence it seems lower than the Jewish norm.
Thus the three groups that constitute the American Jewish community each present significant challenges: The group that is distancing itself from Jewish life and community (often the children of intermarriage, and who often say that they have no religion) needs to be reengaged and reconnected with the Jewish people and the Jewish community as well as with Jewish life and culture. Secondly, the group that had until now constituted the backbone of the Jewish community in America, the Jewish “middle – the Reform and Conservative Jews who belonged to synagogues and Jewish organizations, gave money to Jewish causes, and were very attached to Israel and the Jewish People are shrinking. Thirdly, the Orthodox and in particular, the Ultra –Orthodox who are among the most committed to the Jewish People and Jewish life are insufficiently engaged with the general organized general Jewish community and do not seem to have the wherewithal for continuing the legacy of Jewish influence on the larger American society.
1 The 70-30 split among the Jewish vote goes back to the last decades of the twentieth century. Only in recent years however, has the split been largely according to denominational lines.
2 Rocklin, Mitchell. “Are American Jews Shiftiing Their Political Affiliation?” Mosaic Magazine, January 18, 2017.
3 A Portrait of Jewish Americans, Pew Research Center, 2013.
4 Maltz, Judy. “Clinton Won Overwhelming Majority of Jewish Vote, Polls Say.” Haaretz, November 9, 2016.
5 In 1920, 38% of the Jews voted for Eugene V. Debs, the socialist candidate. http://www.jewishvirtuallibrary.org/jewish-voting-record-in-u-s-presidential-elections.
6 The street demonstrations of the weeks after the election have in the meantime petered out . To a certain extent they have been replaced by meaningful political organization.
7 “New York Police Arrest Some 20 Rabbis Protesting Trump Travel Ban”, Jerusalem Post, Feb. 7, 2017. http://www.jpost.com/Diaspora/New-York-police-arrest-some-20-rabbis-protesting-Trump-travel-ban-480811.
8 Colin Moynihan, “About Twenty Rabbis Arrested During Protest Over Trump Travel Ban,” New York Times, Feb. 6, 2017. https://www.nytimes.com/2017/02/06/nyregion/rabbis-arrested-protest-trump-muslim-ban.html?_r=0.
9 Jewish People Policy Institute, Annual Assessment 2010, p. 169
10 Michael M. Adler, “Jewish Values are to Welcome Strangers, Something Trump Doesn’t Stand For”, Jerusalem Post, Sept. 11, 2016. http://www.jpost.com/Opinion/Jewish-values-are-to-welcome-strangers-something-Trump-doesnt-stand-for-467470.
11 To be sure, in the late nineteenth and during the twentieth Century, the dominant form of Christianity in America was liberal (“Mainline”) Protestantism that embraced liberal values. The liberal Protestant American ambience, which was not altogether secular, encouraged the liberal Jewish strategy of integration.
12 Jacob Katz, Out of the Ghetto, Syracuse University Press, Syracuse New York 1973.
13 Cohen, Eric and Aryana Meisal. “Jewish Conservativism: A Manifesto.” Commentary, April 7, 2017.
14 Of course, one of the factors encouraging the Orthodox approach is the significant strengthening of conservative and evangelical Christianity in America since the 1980’ and the decline of liberal Mainline Protestantism.
15 Huntington, Samuel. Who We Are: The Challenges to America’s Nationai Identity. New York: Simon and Schuster, 2004.
16 Cohen and Maisal, op. cit.
17 Jonathan Haidt, “Moral Psychology and the Misunderstanding of Religion”, The Edge, Sept. 21, 2007. https://www.edge.org/conversation/jonathan_haidt-moral-psychology-and-the-misunderstanding-of-religion (Accessed Aug. 2, 20017)
19 Haidt, Jonathan. The Righteous Mind: Why Good People are Divided by Politics and Religion. New York : Pantheon Books, 2012.
20 Two caveats are here in order. The first is that we are talking about conceptions, values, and norms, not behavior. In any moral system individuals will deviate in their behavior from the accepted norms and values. Nevertheless, we still consider that they adhere to the moral system if they recognize the normative force and claim of the moral values and norms in question. In other words, individuals in a given culture who affirm the moral value of marital fidelity might still commit adultery. They remain in the moral system or culture if, despite their behavior, they recognize the normative force of the prohibition and recognize (on some level) that their own behavior was wrong or deviant.
The second caveat is that we are dealing with ideal types, that is “pure” ideal constructions that have an inner logic to them. These generally do not characterize real populations and real people. Real populations generally carry a mixture of two or more ideal types, even if one ideal type is dominant.
Finally, it should go without saying that our approach is purely descriptive and analytical. We make no claims and stake no position with respect to the moral superiority of one group or approach over another.
21 Exactly who is a freeloader is a politically loaded and contested concept. Some conservatives who focus upon this value tend to stereotypically label whole populations, such as minorities, welfare mothers, youth etc. as freeloaders. See Hochschild, Arlie. Strangers in Their Own Land: Anger and Mourning on the American Right. New York and London: The New Press, 2016.
22 Hochschild, , Arlie. Strangers in Their Own Land: Anger and Mourning on the American Right. New York and London: The New Press, 2016.
23 Haidt, op. cit.
24 President Obama: “In the eyes of God, a child on the other side of the border is no less worthy of love and compassion than my own child,” Obama said. “You can’t distinguish between them in terms of their worth or inherent dignity.” http://edition.cnn.com/2017/05/25/politics/obama-merkel-germany/index.html
25 See for example “Patriotism is our Value, Editorial, The Jewish Star, (Orthodox newspaper published in Long Island), Nov. 23, 2011.
26 Ben Protess, Danielle Ivory and Steve Eder,” Where Trump’s Hands-Off Approach to Governing Does Not Apply”, New York Times, Sept. 10, 2017. https://www.nytimes.com/2017/09/10/business/trump-regulations-religious-conservatives.html?_r=0.