blurb is from OSU's Department of French and Italian:
https://www.nas.org/wp-content/uploads/2023/11/French_Francophone_Studies_Black_France_OSU_Redacted.pdf
https://www.nas.org/wp-content/uploads/2023/11/French_Francophone_Studies_Black_France_OSU_Redacted.pdf
Teams move too soon at the start
False Start: Offense moves too early
Offside: Offensive or defensive player lined up in the zone when ball snaps or crosses the line
Encroachment: Defender touches someone before the snap
NZI: Defender crosses line, makes an O-lineman jump (Neutral zone infraction)
Rules about movement for the offense and defense
For everyone who thinks Nick Shirley was the first person to report on fraud in MN, get a clue. Here’s a very short and not at all comprehensive list of previous reporting from YEARS ago.
1. Jeff Baillon (Fox 9 / KMSP, Minneapolis) – Lead investigative reporter on multiple stories about daycare fraud, including overbilling, kickbacks, cash in suitcases leaving MSP airport, and Somali-owned centers under investigation. Key 2018 piece: “Millions of dollars in suitcases fly out of MSP, but why?” (May 2018; builds on earlier Fox 9 work from ~2013–2015). fox9.com
2. Chris Serres (Star Tribune / Minneapolis Star Tribune) – Covered raids, charges, overbilling at specific centers (often involving Somali operators), and community responses. Example: “May 23: Minneapolis child care center accused of illegally billing state program” (2015, on Salama Child Care Center raid/overbilling). Also reported 2016 charges and 2018 Somali providers’ pushback. startribune.com
3. Scott W. Johnson (City Journal / Power Line) – Independent/policy journalist who wrote on the scale of daycare fraud involving mostly Somali-owned centers and assimilation questions. Article: “Mogadishu, Minnesota” (May 2018). city-journal.org
4. Kim Crockett (Center of the American Experiment) – Policy writer/fellow who covered welfare/child-care fraud, the 2018 Fox 9 reporting, Somali community involvement in cases, and the 2019 legislative auditor review. Piece: “Child care welfare fraud” (Spring 2019, Thinking Minnesota). americanexperiment.org
5. Alpha News / Megan Olson (and related Alpha News coverage) – Local independent outlet that reported on the 2019 Office of the Legislative Auditor findings regarding CCAP fraud allegations (stemming from earlier Fox 9/Somali-linked cases). Article: “Child Care Fraud Confirmed by State Auditor’s New Report” (March 2019). (Liz Collin, associated with Alpha News, has covered related Minnesota fraud extensively in later years; the outlet tracked these issues in the period.) alphanews.org
6. Laura Yuen (MPR News) – Reported on state investigations of the 10 daycare providers (many Somali-owned), official responses to Fox 9 claims, and related context. Example: “Fox 9 reporting on day care fraud called into question” (May 2018). mprnews.org
7. J. Patrick Coolican (Star Tribune) – Covered the 2019 legislative auditor report responding to the 2018 fraud allegations (including Somali-linked cases and unproven terror-funding claims). Article: “Audit: Fraud in Minnesota’s child care program not $100 million but still troubling” (March 2019). startribune.com
8. Bill Glahn (Center of the American Experiment) – Policy analyst who has extensively tracked Minnesota welfare/child-care fraud (including early Somali-linked cases from ~2016 onward); his documentation and commentary reference the 2015–2019 period. Later tracker work builds on that era (e.g., references to 2018 reporting and auditor findings). Example context from his ongoing work: coverage tying back to the period’s cases.
BROS: Mamdani and Trump Think Alike (Like Children) 1. Mamdani: Even though Socialism has a miserable and predictable track record of abject failure everywhere in the world and anytime in history it’s been tried (e.g., Soviet Union, Cuba, North Korea, Venezuela), my new brand of Socialism, for the first time in history, will somehow succeed wildly in NYC thanks to my childlike political “leadership.” 2. Trump: Even though Protectionism has a miserable and predictable track record of abject failure everywhere and anytime it’s been tried (e.g., the Great Depression’s Smoot-Hawley Act), my new brand of Protectionism, for the time in history, will somehow succeed wildly in the USA thanks to my childlike political “leadership.”
Muslim country is warning Europe about Islamism.
Not Christian conservatives. Not the "far right". Not anyone you can wave away as an Islamophobe.
The United Arab Emirates.
The UAE has spent years taking a hard line against political Islam and the Muslim Brotherhood, which the country classifies as a terrorist organisation.
And in June 2026, the UAE's ambassador to the EU, Mohammed Ismail Al Sahlawi, sat in the European Parliament at a conference with this title:
"Muslim Brotherhood: a real threat to Europe."
Hard to misread.
The warning was about the Brotherhood's methods. Infiltrating European societies and institutions, influencing political decisions, spreading extremist ideology.
Read that again.
A Muslim country is warning Europe about political Islam. And here is what matters most! Islamism is not only the man with a rifle or a suicide vest.
That is the outermost, violent expression of it.
Islamism can also work slowly. And politically.
Through organisations, universities, religious institutions, activism, lobbying, political and institutional influence.
That is exactly why it is so dangerous to look only for the man with the bomb belt. Because Islamism can arrive in a suit. It can hold a university degree. It can run an organisation. It can sit close to political decision makers.
And it can learn to speak the West's own language about tolerance, rights and diversity, while working for values that collide with liberal democracy.
And no. This is not just something the UAE claims.
Britain's own government has investigated the Muslim Brotherhood.
The British review found that Brotherhood-associated and Brotherhood-influenced groups in the UK had, at various points, held significant influence over the largest Muslim student organisation, national Muslim organisations in dialogue with the government, charities and some mosques.
The same review concluded that parts of the Brotherhood's ideology and activities run counter to democracy, the rule of law, individual liberty, equality, and mutual respect and tolerance between faiths.
So this is not only about terror.
It is about ideology.
And now comes the part that should stop every European in their tracks.
The UAE has become so concerned about Islamist radicalisation at British universities that British universities have been removed from the list of institutions where Emirati students can receive state scholarships.
Young Emiratis are still free to study in Britain. With their own money. The UAE simply will not pay for it anymore.
A person with direct knowledge of the discussions put it plainly to the Financial Times: "They don't want their kids to be radicalised on campus."
Sit with that for a second.
A Muslim, Arab country is worried about sending its Muslim young people to Britain, because it fears they will be radicalised there.
If that does not trigger some soul-searching in Europe, I don't know what will.
Because the UAE's point is precisely this. You make a fatal mistake if you only start caring about Islamism once someone picks up a weapon.
The ideological process may have started years earlier.
The UAE's foreign minister, Sheikh Abdullah bin Zayed Al Nahyan, has said:
"Daesh, Al Qaeda and other terrorist groups have fed off a wider current of extremist ideas."
He pointed specifically at political Islamist groups such as the Muslim Brotherhood, which in his view have spent decades spreading those narratives.
He called them "backward-looking". And said they "reject open, pluralistic societies." This is a Muslim foreign minister saying it.
And there is something else I want to make very clear!
THE UAE IS NOT THE WEST.
It is not Europe. It is not a Western liberal democracy.
It is a Muslim, Arab country with a different culture, a different form of government and different traditions. And there are aspects of the UAE's political system and human rights record that we would never accept in a Western democracy.
This is not to be romanticised.
But the UAE has fought political Islamism for decades, an ideology its leadership believes has undermined and destabilised the Middle East. And which they now openly warn is seeking influence in Europe and the rest of the Western world.
Their foreign minister has spoken about the need to show that you can be "modern, Arab and Muslim."
That distinction is one Europe desperately needs to understand.
You can be a Muslim and still reject political Islam, extremism, antisemitism and religious intolerance.
And notice one more thing.
THE VIEW OF WOMEN IS PART OF THAT FIGHT.
Abdullah bin Zayed has directly criticised Islamist ideologies for their "denigration of women's role in society."
The UAE has not just talked about it. The country has made women's education, economic participation and leadership official state policy.
Women are to be educated. They are to work.
They are to be able to start businesses. They are to take part economically and politically. And they are to sit at the table where decisions are made.
Sheikh Mohammed bin Rashid Al Maktoum, ruler of Dubai and the UAE's vice president and prime minister, established the UAE Gender Balance Council with the stated aim of reducing the gender gap and strengthening women's participation in leadership and decision making.
And the UAE's president, Sheikh Mohamed bin Zayed Al Nahyan, MBZ, leads a Muslim country that has made religious coexistence part of its national story.
In Abu Dhabi, a mosque, a church and a synagogue stand side by side in the Abrahamic Family House.
Think about that contrast.
A Muslim country is saying: Keep Islam. Fight Islamism.
Let women study, work and lead. Let Christians be Christians. Let Jews be Jews. And fight the political and religious movements that want to replace pluralism with their own ideology.
And yes. That includes the people who support, legitimise and clear the path for those movements while believing they are defending tolerance and diversity. Including when they end up working against the very Western values, freedom, equality, democracy and religious liberty, that gave them the opportunity to do so in the first place.
History has an old term for people who end up serving an ideology whose actual goals they do not share:
"Useful idiots." They do not have to be Islamists themselves. That is the whole point. They only have to be useful to those who are.
And this is what Europe has to learn to separate:
Islam is a religion. Islamism is a political ideology. And Islamist extremism is not "diversity".
You can defend Muslims' full right to believe and practise their faith, and at the same time say a resounding NO to movements that want to use religion for political power, parallel societies, extremism, or the gradual erosion of the society that gave them the freedom to be here.
Tolerance does not mean tolerating intolerance until it has grown strong enough to turn on you.
When a Muslim country pulls its state scholarships away from British universities out of fear of Islamist radicalisation, while parts of Europe are still afraid to even name the problem, the question is no longer whether there is a problem.
The question is who understood the seriousness of it.
And right now, it isn't us!
The exact text in the "Police Anti-Racism Commitment" document confirms that police officers were explicitly instructed not to be color blind.
Even the large body of juvenile-intervention research finds substantial variation. OJJDP notes that only a small percentage of rehabilitative programs used with justice-involved youth have actually been established as evidence-based.
OJJDP is the Office of Juvenile Justice and Delinquency Prevention. It is part of the U.S. Department of Justice.
It is essentially the federal government's juvenile-justice research and policy office. It:
https://x.com/dilanesper/status/2090522889334534259?s=20
OK, so I did a
random search- I searched Westlaw for 2024 asylum cases in the 9th Circuit. I
chose 2024 because that way you can't argue this was due to the Trump
Administration's restrictive policies. These were Biden era cases. And I just
chose the first 10 cases returned.
I didn't ask for
reversals or affirmances. Just for cases that involved review of asylum claims.
And I just took the first 10 that came up. I didn't stack the deck in any way.
And remember, these were the appeals that asylees CHOSE to bring.
So this should be
a somewhat biased sample towards cases with a decent shot of reversal. Because
some litigants facing an obvious loss won't appeal. So let's go through these.
1.
Echeverria
de Leon v. Garland (9th Cir. Jul. 5, 2024) is our first case. Echeverria was
harassed because she would not join a gang. She conceded she had no evidence
that she was ever persecuted because of her membership in a group. Asylum
denied.
2.
.Betancourt v. Garland (9th Cir. Apr. 9, 2024)
comes next. Betancourt said criminals attempted to kidnap her, offering a fake
job at Walmart. However, she "stated that she did not know why she was
targeted and that the criminals attempted to kidnap both men and women"
Denied.
3.
Ayala v. Garland (9th Cir. Dec. 13, 2024) is
next. Ayala "testified that he received no threats or harm since
2007". He conceded he was never personally harmed or threatened in Mexico.
Asylum denied.
4.
Castillo-Lopez v. Garland (9th Cir. Aug. 28,
2024) is next up. Castillo-Lopez actually asserted a claim that would qualify
for asylum if true. He said the FMLN targeted him for participating in a
mayoral campaign. The problem is his story fell apart when he testified. His character witnesses said actually he
participated in the presidential campaign, not the mayoral campaign, and he
couldn't explain the discrepancy. And he changed his story as to whether his
attackers were FMLN members or gang members and who they were. Asylum denied.
5.
Aleman-Belloso v. Bondi (9th Cir. Nov. 13, 2024,
amended Feb. 18, 2025) is next. This has Pam Bondi in the caption because the
opinion was modified (non-substantively) later. But it's still a Biden-era
decision. Aleman-Belloso won his appeal.
(Notice, I am not stacking the deck. If there's a reversal I will tell you
about it.) Aleman was a member of a group of church leaders targeted by the
FMLN. The immigration authorities
misconstrued his position and incorrectly ruled this wasn't a protected social
group. This case got remanded. The opinion reads like he was likely to win his
case on remand, and absolutely should.
6.
Next is Guzman v. Garland (9th Cir. Jun. 11,
2024). Guzman was robbed of her cell phone on the street in 2014, and claimed
this was due to her being a woman. But she admitted she had no idea why the
attacker robbed her. Asylum denied.
7.
Recinos-Orozco v. Garland (9th Cir. Dec. 9,
2024) is our next case. Recinos-Orozco contended throughout her dealings with
USCIS that she had been targeted because she was part of a group of women who
opposed gang violence, but abandoned that claim on appeal. Asylum denied.
8.
He v. Garland (9th Cir. Apr. 5, 2024) comes
next. He was found not to be credible. I'll quote the court on this one.
"She testified that the church she attended in China both did and did not
keep attendance records.... Undated and
unnotarized letters from Petitioner's mother arrived both from mainland China
and from Taiwan, even though Petitioner testified that her mother has never
been to Taiwan.... And Petitioner's
documentary evidence related to her membership in a Los Angeles church included
information that contradicted Petitioner's testimony." "Despite providing a written declaration
stating that she had been... beaten up by the police, Petitioner testified...,
after she was arrested in China, her only contact with the police was when they
released her and that “nothing” happened to her while in custody." Asylum denied.
9.
Calmo-Geronimo v. Garland (9th Cir. Oct. 29).
Calmo didn't even try to win her case. She gave up her argument there was any
nexus between her alleged persecution and membership in a group, and also
didn't challenge the finding that she was lying on her application. Denied.
10.
. Finally, Simonian v. Garland (9th Cir. Dec.
5). Simonian sought asylum even though there was ample evidence his home
government actively investigated the two attacks he alleged (allegations the
immigration officials found not credible anyway). No fear of persecution.
Denied.
So asylum appellees went 1 for 10. A couple ere found on
very credible evidence to be liars. The others were clearly making arguments
about generalized violence and had no basis for claiming credible fear of
persecution based on any group membership. That's the state of asylum. But even more telling is that several of
these people didn't even press their arguments of persecution based on group
membership on appeal. I am an appellate lawyer and I can tell you this is VERY
uncommon in other areas of the law.
Because remember, these people almost certainly were paroled
and got work permits-- almost everyone in the asylum system did. That's the
point of asylum fraud. You might get to stay in the US for several years and
work, until the jig is up. You're just running the clock out.
The
Aleman-Beloso's of the world. Their meritorious cases and appeals take forever
because the courts are clogged with people who just wanted to lie or file a
phony claim to get into the country and get a work permit and make some money.
blurb is from OSU's Department of French and Italian: https://www.nas.org/wp-content/uploads/2023/11/French_Francophone_Studies_Black...