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The Definition Of "Terrorism" Changes By Country

by Alicia Lu

In light of Wednesday's attack on French satirical newspaper Charlie Hebdo and the IED explosion near the NAACP chapter in Colorado Springs, it's been noted that the label "terrorism" has been used in a way that appears arbitrary. For example, media outlets have been liberal with the term when covering the Paris incident, but have exercised restraint in applying the label to the NAACP explosion. According to the U.S. Code's definition of "terrorism," both incidents would qualify. So why the disparity in reporting?

Well, according to international definitions, terrorism means different things in different countries.

After two gunmen stormed Charlie Hebdo's offices and killed 12 people, French President Francois Hollande immediately called the incident a "terrorist attack," as well as prominent publications like the New York Times and Time magazine. When an "improvised explosive device" went off near the NAACP chapter's office in Colorado Springs, Colorado, which the FBI has called "deliberate," only one outlet is calling it a "terrorist attack." And President Obama has not issued any statements on the incident thus far.

The two attacks were very different by all means — the Paris attack killed 12 and was evidently fueled by Islamic extremism, while no one was killed or injured in the Colorado explosion and the suspect's precise motives are still unknown. However, they have at least one thing in common: they are both, indisputably, acts of terrorism, at least according to Title 18 of the U.S. Code. The title defines both international and domestic terrorism as having the following characteristics:

  • Involve violent acts or acts dangerous to human life that violate federal or state law;
  • Appear to be intended (i) to intimidate or coerce a civilian population; (ii) to influence the policy of a government by intimidation or coercion; or (iii) to affect the conduct of a government by mass destruction, assassination, or kidnapping

The only difference between the two is where the violent acts occur. International terrorism happens "primarily outside the territorial jurisdiction of the U.S." while domestic terrorism happens within.

By the U.S.'s definition, then, both Paris and Colorado Springs were hit by acts of terrorism. But when it comes to international media, the disparity becomes even greater.

Responses to the NAACP Attack

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The responses on social media to the NAACP explosion is reflective of the worldwide confusion over what exactly constitutes terrorism. While the media has been careful about labeling it as such, Twitter users are certainly calling it an act of terrorism.

Was the Sydney Hostage Crisis an Act of Terrorism?

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In Australia, terrorism is defined as follows:

An act or threat, intended to advance a political, ideological or religious cause by coercing or intimidating an Australian or foreign government or the public. This action must cause serious harm to people or property, create a serious risk to the health and safety to the public, or seriously disrupt trade, critical infrastructure or electronic systems.

One such action that comes to mind is the recent hostage crisis that took place at the Lindt Chocolate Cafe in Sydney, in which a lone gunman took 18 people hostage and forced them to hold up a black Islamic flag.

How the country labeled the incident varied. Some pointed out the important distinction between a terrorizing act and terrorism, arguing that actions by lone wolves like Man Haron Monis who have no ties to any terrorist organization do not qualify as terrorism. One journalist, Jacqueline Maley, however, asserted that Monis was without a doubt a terrorist, saying, "becoming a terrorist is a matter of doing, not applying."

Elsewhere in the World

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While each country's definition shares some fundamental components, there are also very important discrepancies, no matter how slight.

The European Union defines terrorism as:

[Offenses against people and property that] given their nature or context, may seriously damage a country or an international organisation where committed with the aim of: seriously intimidating a population; or unduly compelling a Government or international organisation to perform or abstain from performing any act; or seriously destabilising or destroying the fundamental political, constitutional, economic or social structures of a country or an international organisation.

The United Kingdom's definition includes similar characteristics, such as intimidating the public, but also sets itself apart by including a term on electronic systems.

The use or threat of action designed to influence the government or an international governmental organisation or to intimidate the public, or a section of the public; made for the purposes of advancing a political, religious, racial or ideological cause; and it involves or causes:
  • serious violence against a person;
  • serious damage to a property;
  • a threat to a person's life;
  • a serious risk to the health and safety of the public; or
  • serious interference with or disruption to an electronic system.

Under the UK's definition, the massive Sony Hack purportedly by North Korea would be categorized as terrorism, something that the U.S. is still divided on.The Arab Convention For the Suppression of Terrorism, which was adopted in 1998, defines terrorism as:

Any act or threat of violence, whatever its motives or purposes, that occurs in the advancement of an individual or collective criminal agenda and seeking to sow panic among people, causing fear by harming them, or placing their lives, liberty or security in danger, or seeking to cause damage to the environment or to public or private installations or property or to occupying or seizing them, or seeking to jeopardize a national resources.

It seems that every definition sums terrorism up as an act that seeks to do harm to people and/or property with the larger intention of intimidating governments, institutions, and peoples. However, a precise, universal definition would be crucial to combat terrorism, because how can you fight something that you can't even define?

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