NPR Under Fire For Calling Woman A Rape “Survivor” Despite Settlement In Favor Of The Accused Columbia Student

NPRLogoWe recently discussed the case of Emma Sulkowicz who gained fame as the “Mattress Girl” for her protest about the handling of her alleged rape by another Columbia student. Columbia not only cleared the male student,Paul Nungesser, of charges but the police refused to bring criminal charges.  Columbia recently settled a civil action brought by the male student and reaffirmed that it found no evidence supporting discipline for sexual assault.  Now,  the Boston-based National Public Radio  station is under fire for a story byNPR correspondent Tovia Smith that continued to refer to Sulkowicz as a “survivor” despite the countervailing findings of the university under the lower “preponderance of the evidence” standard advocated by the Obama Administration. The reference also indicated that Nungesser had indeed raped her.  While the declination to punish Nungesser by the school or the declination to prosecute him does not mean that no rape occurred, it does show that there was insufficient evidence against Nungesser who has always maintained his innocence.

 The story for NPR’s “All Things Considered,” examined a new program called “restorative justice” at schools where the focus is on the harm done “and finding ways to repair it” instead of “judging or punishing the perpetrator.”

Sulkowicz, who carried around a mattress on campus as her protest, was referenced as a “survivor.”

Even under the U.S. Department of Education Office for Civil Rights’ interpretation of Title IX rules, established under then-President Barack Obama, involving a low “preponderance of the evidence” standard for adjudication, Sulkowicz’s complaint did not result in any punishment.

After the outcry, NPR added a clarification to the online version of the story (and it is also posted on the online transcript):

“This story refers to Emma Sulkowicz as a survivor of sexual assault, as she considers herself to be. The accused in her case was found not responsible by a campus adjudication process.”

The reaction of many ranged from deeper confusion to greater outrage.  NPR was suggesting that merely calling yourself a rape survivor warrants the media to use that self-adopted description.  However, that description says that someone else is a rapist and further detaches the reporter from confining reporting to known facts (or to use qualifers).

Later the NPR ombudsman agreed with critics and conveyed a new position of the NPR editors:

Critics were right to be upset. Even though Nungesser was not named in the piece, Sulkowicz and her comment were included, and no mention was made of the outcome of the accusations, even though she was described as a “survivor.”

Newsroom executives told me that they turned to Sulkowicz as an advocate and activist who could speak on how campuses resolve charges of sexual assault. The story did not include details because NPR specifically did not want to reopen the case.

But by calling her a “survivor” and including her comment, NPR did partially reopen the case, however inadvertently. NPR should have anticipated that her story would distract from the main thrust of the piece. It would have been better to find a different interviewee to express qualms about restorative justice in sexual assault cases.

Vickie Walton-James, NPR’s supervising senior editor for national news, agreed, telling me: “In retrospect, maybe she’s not the one we should have used, because she’s become a lightning rod. Her inclusion in the story has distracted from the broader issue of restorative justice.” She added, “It goes without saying there was no intent to be unfair here,” pointing to Smith’s “balanced and outstanding body of work on the issue of campus sexual assault.” Smith, she said (and I agree), “has been out front on the issue of due process rights of the accused and the fairness of campus proceedings.

Notably, however, there is no criticism of the reporting or reporter beyond referring to this error as “inadvertent.”  The deeper concern is with how such stories are reported and the general failure to afford the accused the same level of protection as the accuser.  Accused parties are routinely named as alleged rapists while the names of the alleged victim are withheld. More generally, there has been a comparatively little attention to the due process concerns raised by the Obama Administration initiative.

It was good for NPR to address the issue and there should not be a pile on for the misuse of a single descriptive noun.  However, the response reflects the frustration of some with coverage of this area.

What do you think?


112 thoughts on “NPR Under Fire For Calling Woman A Rape “Survivor” Despite Settlement In Favor Of The Accused Columbia Student”

    1. “Sometimes a defense lawyer will try to put the woman on trial.”

      Slight edit:
      S̶o̶m̶e̶t̶i̶m̶e̶s̶ Always a defense lawyer will t̶r̶y̶ ̶t̶o̶ put the w̶o̶m̶a̶n̶ on trial.

      It’s called the confrontation clause.

      1. Shoot, it left out my inserts:

        S̶o̶m̶e̶t̶i̶m̶e̶s̶ Always a (good) defense lawyer will t̶r̶y̶ ̶t̶o̶ put the w̶o̶m̶a̶n̶ (allegations and credibility of the complaining witness) on trial.

    2. The cases which are tried in front of a petit jury are often the most dubious. Of course the defense counsel ‘puts the woman on trial’. The premise of the defense is that the woman is lying and attempting to send his client to the state penitentiary. What would you expect the defense counsel to do?

    1. mespo – I cannot figure out how it is both a protest and an art project.

          1. deb – Picasso was not at Guenica and there is some suggestion he never visited after the attack.

  1. “This story refers to Emma Sulkowicz as a survivor of sexual assault, as she considers herself to be. The accused in her case was found not responsible by a campus adjudication process.”
    I consider myself to be the King of England. All bow!

  2. If you falsely accuse some human of committing a crime then you should be charged with a crime of false accusation. Your sentence should jive with the sentence imposed on the crime you lied about. So lie about a rape and you get time for having done a rape. Michael Brown’s mother needs to be charged with mothering a felon.

    1. No one found that she falsely accused this man of rape. She didn’t prevail in the campus adjudication system. That does not mean that it didn’t happen. He may have had multiple friends who gave him a false alibi. False reporting is a crime, and if she was guilty of this, they would charge her. I never cease to be amazed at the vitriol against women.

      1. No one found that she falsely accused this man of rape.

        What they found was that she had insufficient evidence to satisfy a ‘preponderance of evidence’ standard administered by people who are commonly biased contra people like Paul Nungesser. That’ll do.

        They did not find beyond reasonable doubt that she’d lied, because that question was never addressed by any adjudicatory authority and such questions are seldom posed. The rest of us can draw our own conclusions from evidence presented in the briefs about the history of contacts between Nungesser and Sulkowicz and the import of that evidence is pretty clear.

        1. Depends on what someone considers sufficient evidence. For someone like you, unless it was on video and witnessed by a busload of nuns, you’d be skeptical. It is a sad reality that people like you, who watch Fox News with its clevage-baring, skin-flashing, CFM-pump-wearing, bottle blondies, don’t have a problem with the credibility disparity in appearance between supposed females and males. Females must bare skin, always sleeveless, never in pants, mostly bleached and heavily made up to be on this network. Men don’t have to do any of this. You don’t find Chump. an admitted serial sexual assaulter, offensive, either. Well, all I can say is this: some day you, your sister, your daughter, or best friend might get raped, and may also be viewed as liars by someone like you and attacked and placed under scrutiny for your every word and action.

          1. Depends on what someone considers sufficient evidence. F

            You don’t get to invent your own reality, Natacha, no matter how much you want that.

            No serious person maintains a conception of human behavior in which a woman is ‘traumatized’ by ‘sexual assault’, then goes about her business normally for weeks (including congenial exchanges with the perpetrator) then suddenly ‘realizes’ she was ‘assaulted’.

              1. Yes, they do. It’s called denial, and it happens all of the time.

                No, it;s not called ‘denial’, which is a popular term for everyday unpleasantness about which people do not wish to mediate.

          2. Then Natcha clearly agrees with Hillary who said: “Every survivor of sexual assault deserves to be heard, believed, and supported.”

            Bill Clinton is a rapist – said multiple women. Do you believe those women? Or do you view all of them as liars who deserve the attacks and assaults they have endured as a result of their accusations?

      1. Anonemouse – wasn’t Dunham the one who admitted molesting her younger sister?

        1. yes, Paul, that was Lena Dunham. Google her father’s “art” and you will come away with a strong suspicion that Ms Dunham did not have a normal childhood, sexually speaking.

    1. Lena,
      If you are correct, your demigod Bill Clinton is a serial rapist.

  3. I used to listen to NPR a lot, but no more. I consider myself to be an NPR survivor.

  4. According to the NCMEC map there are over 861,837 men, women and children (as young as 8 and 10 in some states) required to register and the “crimes” range from urinating in public (indecent exposure), sexting, incest, mooning, exposure, false accusations by a soon-to-be ex-wife, angry girlfriend, or spiteful student, viewing abusive OR suggestive images of anyone 18 years old or younger, playing doctor, prostitution, solicitation, Romeo and Juliet consensual sexual dating relationships, rape, endangering the welfare of a child, the old bate-n-switch internet stings (taking sometimes 12 months before a person steps over the line) guys on the autism spectrum or with intellectual disabilities and many others.

    If you multiply the number on the registry by 2 or 3 family members you can clearly see there are well over 3 million wives, children, moms, aunts, girlfriends, grandmothers and other family members who experience the collateral damage of being murdered, harassed, threatened, children beaten, have signs placed in their yards, homes set on fire, vehicles damaged, asked to leave their churches and other organizations, children passed over for educational opportunities, have flyers distributed around their neighborhood, wives lose their jobs when someone learns they are married to a registrant….all these things occur when these people try to hold their family together and provide the three things that professionals state are needed for successful re-integration; a job, a place to live and a good support system. Residency restrictions, ranging from 500 ft to 2,500 ft are ludicrous and not supported by ATSA.

    The Supreme Court’s Crucial Mistake About Sex Crime Statistics – ‘Frightening and High’ (Debunks the 80% recidivism rate cited by now SCOTUS Justice Kennedy)

    It is very important that you read the abstract below and then the full 12 page essay by Ira Mark and Tara Ellman.
    ABSTRACT This brief essay reveals that the sources relied upon by the Supreme Court in Smith v. Doe, a heavily cited constitutional decision on sex offender registries, in fact provide no support at all for the facts about sex offender re-offense rates that the Court treats as central to its constitutional conclusions. This misreading of the social science was abetted in part by the Solicitor General’s misrepresentations in the amicus brief it filed in this case. The false “facts” stated in the opinion have since been relied upon repeatedly by other courts in their own constitutional decisions, thus infecting an entire field of law as well as policy making by legislative bodies. Recent decisions by the Pennsylvania and California supreme courts establish principles that would support major judicial reforms of sex offender registries, if they were applied to the actual facts. This paper appeared in Constitutional Commentary Fall, 2015.

    A study reviewing sex crimes as reported to police revealed that:
    a) 93% of child sexual abuse victims knew their abuser;
    b) 34.2% were family members;
    c) 58.7% were acquaintances;
    d) Only 7% of the perpetrators of child victims were strangers;
    e) 40% of sexual assaults take place in the victims own home;
    f) 20% take place in the home of a friend, neighbor or relative (Jill Levenson, PhD, Lynn University)

    The public needs to decide if they want to continue to focus on those who, for the most part, are one time offenders or if they see a greater need to fund programs like “Stop It Now” that teaches parents, college students, teens and children about grooming behaviors and other things in their Circles of Safety.

    Women Against Registry ~ Fighting the Destruction of Families

  5. Lena Dunham would LOVE to be a mattress girl if she could ever get someone to have coitus w/ her.

  6. Under this NPR guideline, I want a story about me being a Holocaust survivor. Obama’s unconstitutional policy led to all this victimhood. You should hear Camille Paglia talk about this whiny loser.

  7. Why is everyone upset?

    NPR routinely refers to Juanita Broaderick as a rape survivor, and Kathleen Willey as a sexual assault survivor, don’t they?

    They don’t ? I’m shocked!

  8. Men need to understand that in today’s world, if they commit rape, they will be publicly accused of committing rape.

    1. What needs to be understood is men, via DNA, are often proven innocent of the crime but are still irreparable damaged simply because they were accused. It is not uncommon for them to spend years in jail before being exonerated. It is Extremely Rare for the cops, prosecutors, or the woman (Emma Sulkowicz ) to even offer an apology for destroying someone’s (Paul Nungesser) life.

    2. No one disputes that. They also need to understand that even if they don’t commit rape, they may be publically accused, expelled from school and see their lives destroyed. I remember a time when the left advocated due process for the accused.

    3. And, you need to understand that in today’s world, even if a person hasn’t raped, they can still be accused publicly of rape, and have their lives ruined. And the accuser usually gets off scot free

        1. So now DNA can prove or disprove whether sex is consensual? I try to stay current on science and hadn’t heard about this development.

          1. So now DNA can prove or disprove whether sex is consensual?

            LOL! It can also prove or disprove whether the accused believed the victim to be the age of her online profile.

        2. Sulkowicz lobbed her accusation at Nungesser months later (and after several friendly accusations between them).

          While we’re at it, Paul Nifong had two sets of DNA results on his desk, one which failed to find the DNA of any of 49 Duke lacrosse players in Crystal Gail Mangum’s various orifices and a super-sensitive set that also found no DNA of lacrosse players but did find the DNA of 4 other men. He still secured an indictment of three members of the Duke lacrosse team. The first set of DNA results was a matter of public knowledge in Durham, as was time-stamped security camera footage showing one of the accused at a local ATM at a time when he was supposedly gang raping a a stripper.

          Nifong was re-elected in November 2006. He won 90% of the black vote in Durham. Finding the truth is not the point of some of these exercises.

      1. Most rapists are never reported. Women who have been raped have their lives ruined regardless of what happens to the man who did it.

          1. Here you go:

            The majority of sexual assaults are not reported to the authorities.

            The Bureau of Justice Statistics (BJS) reports that the majority of rapes and sexual assaults perpetrated against women and girls in the United States between 1992 and 2000 were not reported to the police. Only 36 percent of rapes, 34 percent of attempted rapes, and 26 percent of sexual assaults were reported. [3] Reasons for not reporting assault vary among individuals, but one study identified the following as common: [4]
            •Self-blame or guilt.
            •Shame, embarrassment, or desire to keep the assault a private matter.
            •Humiliation or fear of the perpetrator or other individual’s perceptions.
            •Fear of not being believed or of being accused of playing a role in the crime.
            •Lack of trust in the criminal justice system.

            In the NIJ funded Sexual Assault Among Latinas Study (SALAS), it was found that victims did not commonly seek help from the criminal justice system, but did seek informal sources of help such as family and friends. However, one third of the women included in the study did not report their victimization to anyone.

            1. Again, the date the BJS collects is on ‘rapes and sexual assaults’. The compilations of police reports produced by the FBI include only forcible rapes. The former is compiling data on a broader phenomenon.

        1. Women who have been raped have their lives ruined regardless of what happens to the man who did it.

          Are you suggesting we should dispense with the rules of evidence in these cases? Are you as compassionate for the men whose lives are ruined for being falsely accused?

          1. “Rules of Evidence”? Have you studied the Rules of Evidence? Rapes do not happen in public places. Most rapes are never reported. Look it up. Women who have been raped are never the same afterwards, and the reason most of them don’t report the rape is because the don’t want to get victimized a second time by being called a liar and having their lives scrutinized. But, the real story here is the motivation behind publishing this piece: that is to soften the criticism for Chump taking NPR’s funding away. That’s what I mostly have a problem with.

            1. Yes, ‘Rules of Evidence’, Natacha. Those procedural norms applied in trying civil and criminal cases. People who are concerned with practical fact finding respect them. Fact finding is not one of your concerns.

            2. Look it up

              Look it up where, Natacha? It’s a meme peddled in magazine journalism. You might get an idea from looking at the disjunction between self-report studies and compilations of police reports. The trouble is that compilations of police reports (assembled by the FBI) produce data on ‘forcible rape’, whereas the self-report surveys (conducted by the Bureau of Justice Statistics) ask about ‘rape or sexual assault’. (Curiously, the self-report data would indicate a drop in frequency of more than 60% over 20 years, while the police-report data indicate the drop in frequency is on the order of 22%).

            3. Natacha,
              You go on these unhinged rants regarding perceived tyranny with respect to President Trump. Yet you are arguing a position that suspends the rule of law and rules of evidence in favor of a class of victims that you perceive are not receiving justice. Everyone deserves equal treatment under the law. Yes, there are actual rape victims that get no justice for any number of reasons. But when you support setting aside the rules of evidence to aid one victim, you create an environment where no one can have an expectation of justice. That would be actual tyranny.

        2. That’s one theory which may or may not be true, but irrelevant here. The actual issue is NPR’s use of the term “rape survivor” to describe this woman, who has had multiple opportunities to provide proof that she was raped. She has failed to do so, even in the kangaroo court land of campus adjudications. Sexual intercourse that one comes to regret later doesn’t retroactively alter the character of that intercourse. Sexual assault, like any other crime, requires proof. Quite often, the testimony of the complainant alone is enough to garner a conviction, even in the criminal justice system which requires proof beyond a reasonable doubt. Emma’s “proof” was insufficient to overcome the objective evidence, including amongst other things, her post-coital Facebook posts to the alleged perpetrator seeking to be with him again, the fact that she delayed making a complaint for nearly eight months, and the testimony of the alleged perpetrator.
          Further, the New York District Attorney conducted an investigation based on Emma’s complaint to the police, and the DA found that there was not even probable cause (a laughingly-low standard) to continue with the case. Characterizing this individual as a “rape survivor” is not only disingenuous, it’s also a slap in the face to those persons who actually were “raped” in the true sense of the word.

  9. First step is to have local police deal with rape cases. The university is going to be biased as it has skin in the game, and it is, in part, a game. The partying conditions, coupled with over active sexual drives combine to create libidinous chaos. The parents do a less than worthy job sending their kids off to ‘experience’ college. The university falls short by allowing and even encouraging the activities that lead to plain old
    fu*^ing. The civil authorities should be doing the prosecuting and not ‘restoring’ anything. If you rape someone, you go to jail for a long, long, time. If you falsely accuse someone of rape, you go to jail for the same time. There is no one solution but dealing with rape as something other than a heinous crime is not an appropriate foundation for lowering the number of rapes. That’s all that can be done, reduction, not restoration. This is an biased microcosm of our oligarchical macrocosm.

    1. Databases are needed to track repeat offenders and physically constrain them from committing more crimes. It is a complex crime requiring specific interviewing expertise. Most importantly, birth control and termination of pregnancies must be easily available to all women.

      1. Most importantly, birth control and termination of pregnancies must be easily available to all women.

        Not in a decent society they aren’t.

        1. @DSS

          So you’re opposed to making birth control widely/”easily” available?

    2. Issac
      I agree with most of what you say but Never have I read of Anyone going to jail for falsely accusing a man of rape.

      1. solverman

        My point is that there are sometimes mitigating circumstances: both were drunk but one regretted it, etc. However, sex drive is no different than coveting more than one is due and robbing. Some parents bring up their kids with an, ‘attaboy’, attitude regarding sex and some parents bring up kids with a chip on their shoulder and an, ‘well we deserve the nice things in life too’, attitude. Somehow understanding aids the rapist if he is a college student. Rape is still rape, one of the most heinous crimes; the victim suffers permanently. Get robbed and it goes away. Rapists should be put away for lengthy stays if only to deter ‘attaboy’ college football stars. How can a lost football career even compare to getting raped. Rape is a crime and the university has no place judging.

  10. It was good for NPR to address the issue and there should not be a pile on for the misuse of a single descriptive noun.

    Why not? It’s not like it isn’t of a piece with their usual frauds. Go read Fred Barnes’ critique of NPR published 30 years ago in The New Republic (shortly after Barnes had left the Baltimore Sun. They were using red-haze Sandalista as stringers covering the civil war in Nicaragua, and if you ever heard some of those cretins on the air, Fred Barnes reportage on the matter would have come as no surprise to you. Their ‘legal affairs’ reporter was a non-lawyer married to a Democratic member of Congress. For eight years, their chief executive was George McGovern’s quondam campaign manager.

    Go ahead. Pile on.

  11. I think it inappropriate to state that NPR is under fire. They may be “on fire” or have “fire in the engine room” but to say that shots are coming their way is unfair.

  12. Newsflash. NPR is egregious and incapable of serious self-examination. There was ‘no intent to be unfair’; they are simply unfair and incapable of being fair. NPR has an audience because it’s production values are congruent with what educated professional-managerial types want. It has the same assumptions as most of them do, and the remainder put up with NPR because the experience of the rest of the media grates on their sensibilities. The NPR station in your area is also the one likely to have concert and chamber music or jazz.

    Tovia Smith is a peddler of social narratives. Look at her story selection.

    As for Emma Sulkowicz, she’s the daugher of a prominent clinical psychologist in Manhattan. The cobbler’s children go without shoes and the psychologist’s daughter is an insufferable lying head-case. Is it that her father hasn’t the influence over her to shut her up or is it that the headl-shrinker actually believes his daughter? Another adult ‘authority’ figure implicated in this case is the ‘art’ ‘professor’ who supervised her mattress project. The whole episode is a strong argument for closing the studio art program at Columbia (and, let’s be fair, nearly everywhere else) and putting it’s ‘faculty’ out on the curb.

    The whole episode is is a reductio ad absurdam of the feminist outlook on social life. Women have options; men have obligations; and now the option asserted is to replace events with fictions to salve the discontents of young women and to oblige young men to accept punishment for offenses which exist only in the minds of the accuser.

    Paul Nungesser is, by all appearances, an ass who uses women like Kleenex. Sulkowicz wanted a relationship with this ass and he wanted two sexual encounters ‘ere he moved on to his next conquest. If you’d like less of this sort of behavior from men, ladies, quit lying down with them. (Sulkowicz, btw, engaged in sodomy with Nungesser).

    1. DSS – the fact they engaged in sodomy makes gives the ‘mattress girl’ soooo much irony. 😉 Thx for the info.

  13. I agree with solvermn, this was not inadvertent. This was purposeful. I quit listening to NPR when Car Talk became political. That is how bad they are.

    1. Agreed. Since Jim Lehrer’s retirmement, the NewsHour is a study in deceptive framing. Not all that informative, but you can make a drinking game of the salient points Judy and her minions are leaving out.

  14. @solvermn

    It doesn’t matter to leftists if something is factually true or not, what matters is, “does it fit the paradigm?”

    I can think of a dozen other stories where a member of the press either obfuscated or deliberately lied in order to make a point.

    Anyone remember the Trayvon Martin case where the press kept showing pictures of a 12 year, angelic figure, instead of the individual who actually attacked Martin? Or how Zimmerman’s phone call was deliberately edited to make him appear to have stalked Martin?

    And yes, I too, “love” the term undocumented!

    Actually what I like doing is playing the ethnic card with s@@tlibs, when I tell them I’m a Hispanic for Trump. They aren’t sure if they are supposed to hate me or suck up to me as a member of a recognized “victim” group.

    Please, I believe very little when the MSM reports on “hot button” issues and contains a racial or sexual aspect.

    1. The Trayvon Martin case was what convinced me that America was doomed, and had already gone over The Cliffs of Sanity. Now, we are simply waiting to hit the rocks at the bottom.

      Just imagine. Grown up White People putting on hoodies and eating Skittles in remembrance of a mugger, who got shot while banging Poor George Zimmerman’s head into the concrete. Just because Trayvon was black.

      My Crazy Uncle became convinced that America was doomed when he was but a child, and he watched the TV Show, Lost in Space. He was maybe 10 or 12 years old at the time. He could never understand why Dr. Smith, who was constantly endangering the whole family with his antics, wasn’t simply stuffed into the airlock, and sucked out into the cold vaccum of space. Once, he said, the whole family had almost made it back to Earth, yet turned around to go back for Dr. Smith, who had missed the trip trying to do something nefarious. He said he used to wonder if Outer Space had maybe induced some form of Mental Illness on the Robinson Family.

      I saw the show on METV, but could only tolerate 2 or 3 episodes before I became brain dead. When I told him a few months ago about a show called The Hundred, and how they “floated” their miscreants out the airlock, he became excited, and optimistic about America again, and bought me a cheap, used guitar, straight from Soviet Era, in gratitude.

      Which all goes to show the influence that media has on society. I am less hopeful. I think that the only people who will get “floated”, will be white cisgendered people, mostly men.

      Squeeky Fromm
      Girl Reporter

  15. Again, when something likes this happens it makes it harder for a woman who was actually assaulted to get justice.

    1. How does it make it ‘harder’? It may mean that certain sorts of testimony require more skepticism and corroboration. You don’t want to be handing out multi-year prison sentences to people without rigorous procedures applied.

      1. And, right off the bat, you’d rather believe the man than the woman, which says so much about you.

        1. I cannot help you with your reading comprehension problem, tootsie.

          Who I’d ‘rather’ believe is immaterial. You’re projecting. Criminal proceedings have an evidentiary standard of ‘beyond reasonable doubt’. Civil proceedings commonly use ‘preponderance of the evidence’. It doesn’t matter what the crime alleged is or the tort alleged is. (And if its a widespread practice for people to make false accusations, oral testimony loses some of its credibility).

          Sulkowicz could not meet either standard and there are strong reasons to conclude she’s just lying.

  16. This was a flagrant and willful disregard for the truth. It was neither “inadvertent.”  or “a misuse of a single descriptive noun”. This writers words were carefully chosen to misrepresent the truth; just like those who call illegal aliens ” immigrants”. NPR contributed to further damage to Paul Nungesser’s reputation and is subject to penalties for their disregard of the truth.

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