orchestrated or negligently encouraged. The Southern Poverty Law Center has taken the lead in bringing such lawsuits. In 1987, a $7 million judgment bankrupted the Alabama-based United Klans of America for its connection to the lynching of a 19year-old African-American named Michael Donald. In 1990, an Oregon jury rendered a $12 million verdict against the Fallbrook, Californiabased White Aryan Resistance and its leadership for promoting the killing of a young Ethiopian immigrant named Mulegetta Seraw. In 1994, the Church of the Creator — predecessor of the virulently racist World Church of the Creator — lost a million-dollar lawsuit under a Florida state civil RICO law for its part in the murder of a young AfricanAmerican Gulf War veteran, who was killed by a Church “reverend.” In mid-1998, two Carolina Klan groups were held liable for $21.5 million for their connection to the arson of two black churches. Brian Levin testified that successful civil lawsuits have led hate groups to adopt a new strategy of “leaderless resistance,” mimicking a type of guerrilla warfare where individuals or autonomous cells independently undertake violent acts against common enemies without relying on a centralized command and control structure. The concept has been promoted on the neo-Nazi Stormfront Web site and in racist books like “The Turner Diaries” and “The Vigilantes of Christendom.” “Vigilantes” misinterprets the Bible to encourage lone wolves to anoint themselves “Phineas Priests” by committing violence. The strategy guided a convicted felon who robbed banks and attacked abortion clinics. “The Turner Diaries,” a novel revered by white supremacists, has a protagonist who blows up a federal building and randomly targets minorities for murder. The “Diaries” and “Homemade C4,” both readily available for free on the Internet, allegedly inspired the bombing of the federal office building in Oklahoma City in 1995. The convicted murderer of James Byrd in Jasper, Texas, allegedly explained to his cohorts, before they dragged the hapless Mr. Byrd to death behind a pick-up truck, that he was “starting the ‘Turner Diaries’ [revolution] early.” Although the First Amendment to the U.S. Constitution severely limits government censorship, private Internet Service Providers (ISPs) can eliminate anything they deem offensive from their systems. While a few police the content of chat rooms and Web sites, others are philosophically opposed to playing the role of censor or consider it to be an exercise in futility. Most ISPs consider themselves to be mere conduits to the Internet. Moreover, if an ISP shuts down discussion groups espousing racism or intolerance, several more may, in short order, pop up on its network of sites. Web sites that are shut down seem to have little trouble finding new ISPs. ISPs express concern that if they were to start regulating content, it would open the door to all kinds of liability problems. (But see §230 of the Communications Decency Act, which shields ISPs
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