Benchmark - Article Critique
RACIAL PROFILING I SMITH & MASON
The Age of Racial Profiling in the Context of Terrorism Amanda L. Smith and Susan E. Mason
Niagara University
R acial profiling refers to the law enforcement practice o f using only race or ethnicity as probable cause to search or arrest an individual. The public has fo u n d racial profiling to be unjustified in the context o f common crime, but tends to support the practice in the context o f terrorism. The current study uses an explicit ju d g m e n t survey to examine the expression ofprejudice andfactors that influence stereotyping. The study fo u n d that participants aged 1 8 to 24, a n d those who identified w ith a political party, were the participants most likely to racially profile individuals w ith stereotypical M iddle-E astern features to be p o ten tia l terrorists.
Keywords: stereotypes, terrorism, racial profiling, public opinion o f racial profiling
Traditional criminal profiling began w hen law enforcement officers described an individual who had already com m itted a crime (Newman & Brown, 2009; Schildkraut, 2009). A profile, which was given to officers and the public to find a subject, included a physical description, behavioral classifications and social or criminal associations (Newman & Brown, 2009). In the 1980s and 1990s the traditional criminal profile was replaced w ith racial or ethnic profiling (Newman 8c Brown, 2009). T he war on drugs, started by President Ronald Reagan, triggered police officers to tighten control over drug districts, which were unfortunately inhabited by more minority races than Caucasians (Newman 8c Brown, 2009; Schildkraut, 2009). By the end o f the 1990s law enforcem ent was using the highly controversial m ethod o f racial profiling w ith race or ethnicity as the primary factor considered for stop and frisk decisions (Newman 8c Brown, 2009; Johnson et al., 2011; Jadallah 8c el-Koury, 2010). D istrust o f the police began w hen results from numerous studies were released showing th at law enforcem ent unfairly targeted African Americans and Hispanics in a phenom enon that became known as "driving while black" (Newman 8c Brown, 2009).
T h e conceptual framework for racial profiling developed during W orld W ar II w ith
the negative treatm ent o f Japanese and Japanese Americans by the U nited States government and citizens (Johnson et al., 2011). A t th at time the negative stereotypes held by Americans o f an other, alien race were triggered after an event that was perceived as an attack on the in-group. D ue to the level o f violence in the attack, this other race became known as an enemy and was treated as such. T h en w hen the wars on drugs and crime occurred in the 80s and 90s racial profiling became ram pant in law enforcem ent and the general population (Newman 8c Brown, 2009; Johnson et al, 2011). Actions o f ethnic or racial profiling can range from stopping an individual based solely on racial appearance to searching the person or property, placing the individual under arrest or removing the person from the com m unity (i.e., deportation or confinement) (Schildkraut, 2009).
A fter the terrorist attacks in the U nited States on September 11th, 2001, national security was a major concern o f the government and o f US citizens (Hanley, 2012; Newm an 8c Brown, 2009; Zakaria et al., 2002). T h e concept o f "driving while black" changed to "flying while brown" and "walking while Arab" w ith tightened Transportation Security A dm inistration restrictions in airports and threats perceived by the American people on their homeland by Arabs, M uslims and
MODERN PSYCHOLOGICAL STUDIES 75
RACIAL PROFILING I SMITH & MASON
M iddle Eastern descendants (Newman 8c Brown, 2009; Jadallah 8c el-Koury, 2010 ; Zarom b, Butler, Agarwal 8c Roediger 2014). Although terrorism is not a new form o f warfare unique to the 20th and 21st centuries, scholars still struggle to develop a precise definition that takes into consideration the requirements, purpose and agents who participate in terror tactics (Onwudiwe, 2005). T he most basic definition th at m ost scholars and experts agree on is that terrorism is the threat or use o f violence on an audience w ith the intention o f causing fear in a target group for political, religious or other ends. Eliciting fear in a population is a strong motivator for that group to listen to the perpetrator and can serve as a trigger for patriotism and an increase in prejudice against the other group (Oswald, 2005). However, terror acts are not easily restricted to a certain social group. T h e uncertainty o f who the perpetrators are, and could be, heightens the fear felt by the population. Social bonds between in-group individuals are strengthened, and out-group derogation results from the combination o f group cohesion and perceived threat (Oswald, 2005).
In 2000 there were 354 reported attacks on individuals o f M iddle Eastern descent and M uslims (Oswald, 2005). A fter the 9/11 terror attacks there was an explosion o f hate crimes against M uslims and those categorized as Arab (Hollenbaugh, 2009). In the weeks after 9/11 a confirmed total o f 27 individuals were banned from airlines purely because o f their Arab race and there were 520 recorded, or reported, violent hate crimes on persons labeled by the perpetrators as M iddle Eastern. By the end o f 2001 there were 1,501 attacks reported - a substantial increase th at could reasonably be attributed to the events o f 9/11 (Oswald, 2005). Directly after 9/11, public opinion polls dem onstrated a sharp increase in support for the use o f racial profiling by law enforcem ent to prevent another terror attack
(Hanley, 2012; Jadallah 8c el-Koury, 2010; Jonson et ah, 2011; Newm an 8c Brown, 2009; Zakaria et ah, 2002). T h e percentage o f Americans who disapproved o f the process had been around 60% before the attacks, and after 9/11 the approval rating was measured to be 80% (Jadallah 8c el-Koury, 2010). These percentages did not just reflect immediate reaction to the terror attacks o f September 11th, but were relatively consistent over the next couple o f years (Johnson et ah, 2011). Even before 9/11 Americans began to equate M uslim w ith Arab (Suleiman, 1999). This can still be seen over a decade later. Both groups are viewed as alien and other, and the two categories have been used interchangeably to describe a new threat from the M iddle Eastern region (Suleiman, 1999; Jenkins, Ruppel, Kizer, Yehl 8c Griffin, 2012).
As the nation's negative view o f Arabs, Muslims and those o f M iddle Eastern descent worsened, the use o f racial profiling by law enforcem ent in the context o f terrorism became an issue. T h e traditional criminal profile m orphed once again, only after 9/11 the profile created was for a suspected terrorist (Newman 8c Brown, 2009). Terrorist profiling is defined as the suspicion o f a person being involved in a terrorist act because o f physical characteristics and behavioral cues (Newman 8c Brown, 2009). T h e use o f a profile that takes into account social connections and behavioral cues along w ith racial descriptions is considered acceptable; but an issue arises when an official uses race as the main reason for suspecting an individual o f involvement in a terror plot. There is no evidence that suggests the use o f racial profiling works in the context o f crime, or in the context o f terrorism (Hanley, 2012; Newm an 8c Brown, 2009; Johnson et al., 2011; Schildkraut, 2009; Zakaria et al., 2002). Race is too broad o f a category, and too dependent on social definitions, to be o f much use in searching for criminal suspects (Zakaria et al., 2002). I f
MODERN PSYCHOLOGICAL STUDIES 76
RACIAL PROFILING I SMITH & MASON
officials focus on the race o f an individual when searching, it can become a distraction from the reality o f the situation (Zakaria et ah, 2002).
W hile the act o f terrorism has been around for centuries, the majority o f psychological research on the topic has occurred w ithin the last twenty or thirty years (Newman 8c Brown, 2009; Johnson et ah, 2011). There has been substantial research on the effects and uselessness o f racial profiling in the context o f com m on crime by law enforcem ent and w hether the public finds the use o f racial profiling by officers to be justified in either context (Jadallah 8c el-Koury, 2010 ; Johnson et ah, 2011; N ewm an 8cBrown, 2009; Onwudiwe, 2005; Reitzel 8c Piquero, 2006; Sulieman, 1999; Zakaria et al., 2002; Zarom b et al., 2014).
W h a t is currently lacking in psychological literature is research on the general public's use o f these racial techniques outside o f law enforcement. H ere racial profiling is not in relation to protecting the borders where extreme caution is taken by officials who screen those coming into the country. It is purely racism or prejudice against an individual the public has labeled as Arab, or M iddle Eastern or M uslim. This is the racial profiling that can be harmful to the country, resulting in hate crimes and alienation o f innocent persons, and can lead to the national security and safety concerns that are stated as the reasons for profiling in the first place.
Race o f the respondent is the most consistent predictor o f attitude toward the use o f racial profiling (Jonson et al., 2011). W hites are m ost likely to approve the process in preventing crime and terrorism (Jadallah 8c el- Koury, 2010; Johnson et al., 2011; Schildkraut, 2009). This is also seen in airport security situation studies where minority group members are significantly less likely to justify the use o f racial profiling at airports (G abbidon et al., 2009). Research has also shown that older adults are more likely than younger adults
to justify racial profiling by law enforcem ent in the name o f national security, and more likely to express prejudicial views (Johnson et al., 2011; Reitzel 8c Piquero, 2006; Oswald, 2005; Schildkraut, 2009). M en are found to be more in support o f racial profiling than women (Johnson et al., 2011; Schildkraut, 2009), and those who identify as conservatives are more likely than those who consider themselves liberals to justify the use o f racial profiling in the context o f terrorism (Johnson et al., 2011; Reitzel 8c Piquero, 2006; Schildkraut, 2009).
T h e social norm o f a group is another predictor o f expressed prejudice (Crandall, Eshleman 8c O'Brien, 2002). I f a group is against those who fit the stereotype o f Arab, then discrimination and racial profiling will be seen more often. Individuals w ith lower levels o f education, those located in the Southern region (versus N orthern region) o f the U nited States and W estern and Internationally- located respondents all show a greater prevalence o f prejudice in the context o f terrorism (Oswald, 2005). T h e vast majority o f Americans find racial profiling in the context o f terrorism to be more useful and more justifiable than its use by police in the general context o f crime (Jadallah 8c el-Khoury, 2010; Johnson et al., 2011; Newm an 8cBrown, 2009; Schildkraut, 2009; Suleiman, 1999).
T h e aim o f the present study was to further advance our understanding o f the factors that contribute to an individual’s use o f racial profiling in the context o f terrorism. A n explicit judgm ent survey was used to assess individuals’ perceptions o f those o f M iddle Eastern descent. In addition, age and political affiliation were examined as contributing factors to individuals’ use o f racial profiling in the context o f terrorism. Based on the current literature in the fields o f psychology, political science, sociology, criminology and criminal justice, it was hypothesized that racial profiling o f stereotypical M iddle-Eastern individuals as potential terrorists would be more common in
MODERN PSYCHOLOGICAL STUDIES 77
RACIAL PROFILING I SMITH & MASON
older as compared to younger adults, and more com m on in those who identify themselves as having conservative views as compared to those who identify themselves as having liberal views.
Methods
Participants
A total o f 270 individuals participated in the present study. Volunteers were recruited from university classrooms (195 participants aged 18-24 years) and from community groups (25 participants aged 25-44; 20 participants aged 45-64; 30 participants aged 65 or older).
In the student sample there were 68 men and 127 women. Based on their responses to a demographic questionnaire, 81.1% o f the student participants were Caucasian, 7.7% were Black or African American, 4.6% were Hispanic, 3.6% were Native American or Indigenous/ Aboriginal, 1.5% were Asian or Pacific Islander and 1% identified as Arab or M iddle Eastern. O f the students included in the sample, 23.5% identified as Republican, 26% identified as Dem ocrat, 17.3% identified as Independent, 31.1% identified w ith no political party, and a small percentage (2%) selected an "other" category.
T he com m unity sample included 26 men and 48 women. Based on self-report data, the com m unity sample was 90% Caucasians, 5.3% Black or African Americans and 2.7% Hispanics. O f the community participants, 42.5% identified as Republican, 26% identified as Dem ocrat, 12.3% identified as Independent, 16.4% identified as having no political affiliation, and a small portion (2.7%) identified as belonging to an "other" party. Procedure
A fter responding to demographic questions, participants were given a six-page booklet. Each o f the six pages included six black-and-white headshots. For each group o f
six pictures, participants were asked to select the individual they believed to most likely be the terrorist in the group.
All 36 o f the pictures in the booklet were photographs o f known terrorists. Based on physical characteristics, 14 were classified as Caucasian, 12 as M iddle-Eastern, 7 as Asian, and 3 as Hispanic. All 36 were men. T he identities o f the terrorists were verified and the profile pictures were obtained from the FBI's M ost W an ted Terrorists listing online and a search o f names gathered from w w w .start.um d.edu/gtd and www.rand.org/ nsrd/projects/terrorism - incidents.htm l, which included members o f the Japanese Red Army and the Irish Republican Army. Pictures were cropped or enlarged for consistency o f presentation; no other alterations were made.
Results and Discussion
Profiling Score
T h e num ber o f times a participant identified an individual w ith stereotypical M iddle-Eastern physical characteristics as the likely terrorist was compared to the num ber o f times a participant chose a Caucasian. T he difference between those two numbers was considered the participant’s “profiling score”. Table 1 displays the profiling score means and standard deviations for each age group.
A single-sample t test was used to compare the sample profiling scores to a population value o f zero. It should be noted th at to use zero as the comparison value is to take a conservative approach, given th at there were more Caucasian pictures included in the questionnaire and chance responding would have resulted in a negative profiling score rather than zero.
Significant profiling was found in both the student sample (/ (194) = 6.525, p < .001, 95% C l: [1.064, 1.987]) and in the community
MODERN PSYCHOLOGICAL STUDIES 78
RACIAL PROFILING I SMITH & MASON
sample as a whole (t (74) = 2.272, p = .026, 95% C l: [.099, 1.502]). Participants in each group were more likely to identify those w ith a M iddle-Eastern appearance as terrorists. Unexpectedly, the profiling scores o f the students and the youngest com m unity group were twice as high as the profiling scores o f the two oldest com m unity groups. This finding is inconsistent w ith previous research, which has shown older adults to be more likely than younger adults to justify racial profiling. T he relatively low profiling scores o f older adults may be explained, partially, by the fact that the older adults were more likely to have recognized one o f the Caucasian terrorists, T im othy McVeigh.
T im o th y M eV eigh
T im othy M cVeigh was a white male in his early-twenties from Lockport, a city in western New York only 20 miles from the primary data collection site for the present study. O n April 19th, 1995 McVeigh, along w ith accomplice Terry Nichols, planted a bomb in a truck parked in front o f the Alfred P. M urrah Federal Building in Oklahom a City. T he bomb blast resulted in over 165 deaths and buildings in a 16-block radius surrounding the Federal Building were destroyed or damaged. B oth M cVeigh and Nichols were arrested and convicted. M cVeigh was sentenced to death and died in 2001; Nichols was sentenced to life in prison. T h e Oklahom a C ity bom bing to this day is the largest domestic-based terror attack recorded in the U nited States. Tim othy M cVeigh and Terry Nichols were 2 o f the 36 terrorists included in the study.
A forward logistic regression was conducted to determine which independent variables (age, gender, if participants watched the news, and if any faces presented in the survey were familiar to the participant) were predictors o f identifying T im othy M cVeigh as a likely terrorist. Regression results indicated the
overall model fit o f two predictors (age and a familiar face was seen in the survey) were statistically reliable (A2 (5) = 52.390, p < .001, 95% CL [.075, .625]). T h e model correctly classified about 86% o f the cases analyzed. Wald statistics indicated th at age o f the participant, and if a participant indicated a familiar face was seen, were significantly predictive o f identifying T im othy M cVeigh as a terrorist.
A comparison o f the frequencies dem onstrated that the predictive factor o f age group for the choice o f T im othy M cVeigh was strong. O f the overall population sampled, a total o f 17.7% o f participants chose Tim othy M cVeigh. T h e percentage was lowest for the students aged 18-24 years (10.9%); higher for the com m unity members aged 25-44 years (28.6%); even higher for the community members aged 45-64 years (38.9%); and highest for the com m unity members aged 65 years and older (42.3%).
Despite the fact that more pictures o f Caucasians were included than pictures o f M iddle Easterners, and one o f the Caucasians was recognized by some to be a known terrorist, each o f the age groups dem onstrated racial profiling. T h a t the experiment yielded these results in 2015, fourteen years after the incidents in 2001 on September 11th, is an indication o f the strength and endurance o f stereotypes. T h e violence and devastation to the U nited States o f the terror attacks on the W orld Trade Centers in N ew York City, the Pentagon and the tragic heroism o f Flight 93 had such a significant impact th at most Americans remember where they were, w hat they were doing and w hat happened afterward to this day. I f the media's stories were tracked, the mainstream news outlets would m ile-m ark the year and remembrance ceremonies around the country on 9/11 every year. Families o f the victims would be seen and memories rehashed the whole day, always connecting the terror attacks to A l-Q aeda in the M iddle-East, and
MODERN PSYCHOLOGICAL STUDIES 79
RACIAL PROFILING I SMITH & MASON
to the perpetrators who infiltrated our country to learn and then attacked innocent civilians from w ithin our borders. These sentiments and honors to the victims and their families are certainly justified. Yet, the complete and unrelenting anger and discrimination o f a very vaguely defined 'race' or ethnicity is not justifiable. T he present study dem onstrated a prejudice against M iddle-Eastern individuals, and that prejudice was seen across age groups. W hile younger adults may report a disapproval o f racial profiling in the context o f common crime and to a lesser extent in the context o f terrorism, they did rely on a stereotype when identifying a terrorist.
Political Affiliation
Unexpectedly, there was no significant difference (/ (94) = .824, p = .412, 95% C l: [- .755, 1.826]) between the profiling scores o f students who identified as Democrats (N = 51, M = 1.726, SD = 3.418) and those who identified as Republicans (N = 45, M = 2.261, SD = 2.932). For many people, the Democrats in the U nited States represent the fight against discrimination o f any kind, but especially w ithin racial relations. It is this common understanding that makes the results found intriguing. O ne plausible explanation is that the topic o f terrorism is highly controversial and complex because o f the high level o f fear associated w ith the acts recognized as terror attacks. T h e sense o f being "American" and national singularity against an enemy other may trum p any race ideologies in the context o f terrorism. T he violence o f the attack may also have a strong influence on an individual's prejudicial expressions.
A n independent-sam ples t test compared the mean profiling scores o f the students who identified w ith a political party (Republican or Democrat; N = 96) to those who identified w ith no specific political ideology (Independent or no political affiliation; N =
95). T h e independent-samples t test found a significant difference between the means o f the two groups (t (189) = 2.201, p = .029, 95% Cl: [-1.933, -.106]). T h e mean o f the political affiliation group (M = 2.019, SD = 3.156) was significantly higher than the mean o f the group th at had no political affiliations (M = 1.00, SD = 3.329).
A n independent t test was also used to compare the mean profiling scores o f the community group members (aged 25 and older) who identified w ith a political party (M = .280, SD = 3.003) and those who did not identify w ith a political organization (M = 1.809, SD = 3.076). A marginally significant difference was found in the same direction as was found in the student sample. Com m unity participants who did not identify as Democrats or Republicans were less likely to use profiling than those who did (/ (69) = 1.945, p = .056, 95% C l: [-3.099, .039]).
T h e finding that those who identified as Independents or as having no political affiliation had lower profiling scores may indicate that profiling in the context o f terrorism is lessened in those w ith weaker political-social connections because they do not hold the social definitions associated with a particular political ideology. In the U nited States social groups are partially defined by the political party or political ideas held by the group members. Therefore, it is reasonable to assume we are more likely to converse about deeper issues and socialize over longer periods o f time w ith individuals who share our political and social beliefs. Previous research has shown conversations am ongst peer groups have a strong impact on the details remembered and the formations o f a common frame o f reference against which new information is viewed. Thus, those w ith similar perceptions o f the world may reinforce historical representations o f an other race or ethnicity and continue prejudice as a result. By having such drastic views w ithin our political sphere, if one
MODERN PSYCHOLOGICAL STUDIES 80
RACIAL PROFILING I SMITH & MASON
belongs to a specific party than he or she is in increased and constant contact w ith individuals who share a similar worldview and segregated from those who have a different point-of-view. W e tend to share more in a conversation w hen we agree w ith those in the discussion, while rem aining silent on topics when we find ourselves in disagreement. I t can be seen th at those participants who identified as belonging to no political party had lower profiling scores. This same grouping o f individuals has no significant political force alienating them from others due to a constructed social group.
Conclusions
T h e present study dem onstrated racial profiling o f M iddle Eastern individuals in the context o f terrorism. Profiling was more likely to occur in the younger age groups than in the older age groups, and it was more likely to occur in individuals affiliated w ith a major political party than those who did not claim party affiliation. T h a t prejudice exists in m odern America is a fact that is clearly understood w hen discussing white and black color lines and the context o f common crime. However, because o f the nature o f terrorism and the fear it produces in the target population, prejudice in this context receive less attention. T h e use o f racial profiling in the context o f terrorism can be just as harmful as it is in any other context. H undreds are targeted based solely on their race or ethnicity. N o t only are the persons experiencing discrimination in their lives h u rt by the use o f the practice, the individuals condoning or participating in the use o f such prejudice are as well. T h e continued, unfiltered use o f cognitive frameworks based on negative historical representations o f M iddle-Eastern individuals can perpetuate violence and those joining terror groups. Negative stigma and biased media accounts o f past and recent events can
also contribute to a cycle that is counterproductive to combating terrorism.
I t is recommended that future research focus on racial profiling in the context o f terrorism. I f the goal is to reduce or eliminate profiling in that context, it will be im portant to gain a better understanding o f the prejudices held against the M iddle East and the land’s people. By determ ining how those prejudices are formed and maintained, it may be possible to develop m ethods to reduce the prejudice that underlies racial profiling.
References Crandall, C. S., Eshleman, A., & O'Brien, L. (2002). Social
norms and the expression and suppression o f prejudice: The struggle for internalization. Journal o f Personality and Social Psychology, 82, 359-378. doi:10.1037/0022- 3514.82.3.359
Gabbidon, S. L. (2009). T he influence o f race/ethnicity on the perceived prevalence and support for racial profiling at airports. Criminal Justice Policy Review (0887- 4034), 20, p. 344.
Hanley, D. C. (2012). It's time to end racial, religious and ethnic profiling o f Americans. Washington Report nn Middle East Affairs, 31, 27-28.
Hollenbaugh, R. A. (2009). Pearl harbored: Race, gender and public memories o f Pearl H arbor and 9/11/2001. Dissertation Abstracts International Section A, 70, 3207.
Jadallah, D ., & el-Khoury, L. (2010). State power and the constitution o f the individual: Racial profiling o f Arab Americans. Arab Studies Quarterly, 32, 218-237.
Jenkins, W . J., Ruppel, S. E., Kizer, J. B., Yehl, J. L., & Griffin, J. L. (2012). A n examination o f post 9-11 attitudes towards Arab Americans. North American Journal o f Psychology, 14, 77-84.
Johnson, D., Brazier, D., Forrest, K., Ketelhut, C., Mason, D., & Mitchell, M . (2011). Attitudes toward the use o f racial/ethnic profiling to prevent crime and terrorism. Criminal Justice Policy Review, 22, 422-447. doi: 10.1177/0887403410381801
Newman, D. W ., & Brown, N. D. (2009). Historical overview and perceptions o f racial and terrorist profiling in an era o f homeland security: A research note. Criminal Justice Policy Review, 20, 359-374.
Onwudiwe, I. D. (2005). Defining terrorism, racial profiling and the demonisation o f Arabs and Muslims in the USA. Community Safety Journal, 4, 4-11.
Oswald, D. L. (2005). Understanding anti-Arab reactions post-9/11: T he role o f threats, social categories, and personal ideologies. Journal o f Applied Social Psychology, 35, 1775-1799.
MODERN PSYCHOLOGICAL STUDIES 81
RACIAL PROFILING I SMITH & MASON
Reitzel, J., & Piquero, A. R. (2006). Does it exist? Studying citizens' attitudes o f racial profiling. Police Quarterly, 9, 161-183. doi:10.1177/1098611104264743
Schildkraut, D. J. (2009). T he dynamics o f public opinion on ethnic profiling after 9/11: Results from a survey experiment. American Behavioral Scientist, 53, 61-79.
Suleiman, M . W . (1999). Islam, Muslims and Arabs in America: T he other o f the other o f the other. Journal of Muslim Minority Affairs, 19, 33.
Zakaria, F., Underwood, A., Ali, L., Chong, J., El Sawy, N., Campo-Flores, A., 8 c ... Wingert, P. (2002). Freedom vs. security. Newsweek, 140, 26.
Zaromb, F., Butler, A., Agarwal, P., 8c Roediger, H. (2014). Collective memories o f three wars in United States history in younger and older adults. Memory & Cognition, 42, 383-399. doi:10.3758/sl3421-013-0369-7
Appendix
Sample Size_____M ean
Table 1 P r o filin g Scores Age G roup 1 8 - 2 4 years 25 - 44 years 45 - 64 years 65 and older
195 1.526 25 1.200 20 .600 30 .600
Standard Deviation 3.273 3.559 3.362 2.372
MODERN PSYCHOLOGICAL STUDIES 82
Copyright of Modern Psychological Studies is the property of Modern Psychological Studies and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use.