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Joe Biden leaves a complicated legacy on the federal courts

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theconversation.com – Paul M. Collins Jr., Professor of Legal Studies and Political Science, UMass Amherst – 2025-01-16 07:54:00

Clarence Thomas shakes hands with Joe Biden, then-chairman of the Senate Judiciary Committee, before Thomas’ Sept. 10, 1991, confirmation hearing to be an associate justice of the Supreme Court.
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Paul M. Collins Jr., UMass Amherst

President Joe Biden’s farewell to elected office on Jan. 20, 2025, presents an opportunity to reflect on the legacy he left on the federal courts.

Many will perceive Biden’s influence on the courts primarily based on his appointment of Ketanji Brown Jackson, the nation’s first Black, female Supreme Court justice.

But Biden’s judicial legacy spans decades and reaches far beyond the makeup of the current Supreme Court.

As a leading scholar of the federal courts, I believe Biden’s judicial impact is most notable in three regards: his role in the 1991 confirmation of Clarence Thomas, his historic efforts during his presidency to diversify the federal bench, and his 2024 decision to veto legislation expanding the number of federal district court judgeships.

A woman in a black jacket and a man in a blue suit standing outside applaud.
Biden appointed more women to the federal bench than any other president, including Ketanji Brown Jackson, shown here with Biden on April 8, 2022, after the Senate confirmed her appointment as the first Black woman to sit on the U.S. Supreme Court.
Chip Somodevilla/Getty Images

Chairman Biden’s impact

When he was a senator, Biden served as the chair of the Senate Judiciary Committee from 1987 to 1995. During that time, Biden oversaw the Senate’s consideration of hundreds of federal court appointments, including six Supreme Court nominees.

His role in the 1991 confirmation hearing of Supreme Court Justice Clarence Thomas stands out for how he handled allegations of sexual harassment brought against the nominee.

Thomas was appointed by President George H.W. Bush to replace Thurgood Marshall, a liberal icon and the nation’s first Black Supreme Court justice.

Replacing the liberal Marshall with the conservative Thomas had the potential to shift the ideological makeup of the court. As a result, Thomas’ confirmation hearing was sure to be contentious.

But things got especially heated when Anita Hill, a former colleague of Thomas, alleged that Thomas had sexually harassed her when they both worked at the Department of Education and at the Equal Employment Opportunity Commission.

As chairman of the committee, it was ultimately up to Biden how to handle the investigation of these allegations.

Perhaps Biden’s most controversial decision involved his refusal to allow senators to hear from witnesses who were willing to testify under oath to corroborate Hill’s allegations. In a 2017 interview, Biden said that the witnesses backed out at the last minute. But this explanation is contested by at least one witness, who said she was never called to testify.

Though we’ll never be sure, this testimony could have sunk Thomas’ confirmation. Instead, he was confirmed by a 52-48 Senate vote.

Much later, Biden recognized that his handling of Hill’s allegations was going to be an issue in his 2020 presidential campaign. As a result, Biden reached out to Hill before announcing his candidacy. In that phone call, he expressed his regret for what she experienced at the hearing, but he did not go so far as to apologize.

Biden’s federal court appointments

As president, Biden’s primary legacy involves his historical efforts to diversify the federal bench in terms of the race, gender, sexual orientation and religion of his judicial nominees.

Biden appointed more women to the bench than any president before him, as well as the most racially and ethnically diverse group of judges in the nation’s history. Biden also appointed an unusually large number of former public defenders to judgeships.

Jackson, as a Black woman and former public defender, is the most high- profile example of this. But Biden also nominated more than a quarter of all sitting federal judges in his four years a president.

Biden’s efforts to diversify the federal bench are important and are likely to be tangible.

Having diverse judges on the courts increases support for courts among women and people of color. This is significant, since courts rely on the public for their legitimacy, and America has become increasingly diverse over time.

Female judges and judges of color tend to be more progressive in their decision-making than other judges, more often supporting litigants claiming violations of their civil rights. This is especially true for areas in which such judges may have unique perspectives and experiences, such as gender and racial discrimination.

Similarly, research shows that judges who were once public defenders are less likely to incarcerate convicted criminals and tend to hand down shorter sentences among those sentenced to prison.

The future of federal courts

Biden vetoed a bill to add dozens of new federal judges to the bench, apparently fearful that Donald Trump would get to appoint them.

One of Biden’s lesser known, but very substantial, final acts in office involves vetoing the JUDGES Act of 2024.

This legislation would have added 66 judges to the federal courts. Some of those courts are currently understaffed, resulting in heavy workloads for judges, creating delays in the administration of justice.

Though the bill had unanimous support in the Democratically controlled Senate in August 2024, the Republican-led House refused to vote on the bill until after the 2024 election.

This was a strategic move that would ensure that the winner of the election – Donald Trump – would appoint the initial batch of 25 judges under the legislation.

Biden said that he vetoed the legislation because there were some lingering questions that should be answered, such as how the new judgeships would be allocated to courts across the country.

But as a scholar of the federal courts, it is evident to me that Biden’s real motivation was to prevent Trump from appointing the first 25 judges.

Taken as a whole, Biden leaves a complicated legacy on the federal courts. On the one hand, he undertook unprecedented efforts to ensure that the federal courts look like the people they represent. He also resisted efforts that would have moved the courts in a conservative direction under Trump’s second term.

On the other hand, Biden played a major role in the confirmation of Thomas, one of the most conservative justices in American history.The Conversation

Paul M. Collins Jr., Professor of Legal Studies and Political Science, UMass Amherst

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Israel-Hamas deal shows limits of US influence – and the unpredictable impact of Trump

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theconversation.com – Gregory F. Treverton, Professor of Practice in International Relations, USC Dornsife College of Letters, Arts and Sciences – 2025-01-16 17:54:00

Relatives and supporters of Israeli hostages held in Gaza gather in favor of the ceasefire deal in Tel Aviv on Jan. 16, 2025.
Jack Guez/AFP via Getty Images

Gregory F. Treverton, USC Dornsife College of Letters, Arts and Sciences

A ceasefire deal between Israel and Hamas is expected to take effect on Jan. 19, 2025, according to U.S. Secretary of State Antony Blinken. Even as Israel’s cabinet delayed until Jan. 17 its vote to ratify the complex deal, Blinken said he is “very confident this is moving forward.”

The U.S., Qatar and Egypt helped broker the deal, which followed negotiations that had many starts and stops in 2024. Representatives of the Biden administration and President-elect Donald Trump worked together to advance the agreement, and both leaders took credit for the expected return of an estimated 100 Israeli hostages – both living and dead – and a complete ceasefire in the Gaza Strip.

Amy Lieberman, a politics and society editor at The Conversation, spoke with Gregory F. Treverton, who served as the chairperson of the U.S. National Intelligence Council during the Obama administration, to better understand what the United States’ role in this agreement says about American influence in the Middle East.

A white man with a dark suit stands at a podium and raises a finger. Two people, one man and a woman, stand behind him, alongside an American flag.
President Joe Biden, flanked by Vice President Kamala Harris and Secretary of State Antony Blinken, delivers remarks on the ceasefire deal between Israel and Hamas on Jan. 15, 2025.
Anna Moneymaker/Getty Images

What is unusual, if anything, about the role of the US in this deal?

So far, the U.S. has not had very much influence in attempts to end the conflict. One reason is that Israeli Prime Minister Benjamin Netanyahu appears allergic to taking advice from the U.S. What is striking now is that some combination of Donald Trump coming to power and Joe Biden leaving office has made a difference – and possibly made Netanyahu more willing to take political risks with his governing coalition and to sign on to the deal.

It is more or less the same kind of deal that the U.S. presented in May 2024. So, it is hard to know whether Trump moved the dial by his past threats to punish Hamas and by pressuring Netanyahu, or whether Hamas felt like it has been weakened and lacks outside support from weakened allies like Iran. Or a combination of these factors.

We also know that there are some last-minute hiccups with the deal, so it isn’t over yet. But there is real progress and hope, and that reflects a lot of the Biden administration’s hard work over the past 15 months.

The proposed deal has three phases that will last more than four months. Because it starts doesn’t mean it will get to the end. And the agreed end is very, very vague, with a revamped Palestinian Authority taking over Gaza – something Netanyahu has said he doesn’t want.

The deal has been brokered largely by the U.S., Egypt and Qatar. There is not a serious international monitor of the deal beyond the political pressure of these countries.

Many destroyed buildings are seen on a gray day. People walk past outside stalls on a street.
People walk past rubble and destroyed buildings in Khan Yunis, Gaza Strip, on Jan. 15, 2025.
Bashar Taleb/AFP via Getty Images

What do you make of Trump’s and Biden’s teams working together on this?

It is not unprecedented. Typically, during ordinary transitions between administrations, there is a lot of cooperation and working together.

What is unusual is that you would perhaps not have expected this kind of collaboration, given the hostility between Trump and Biden and their teams. Biden has said that his administration and the Trump team have been “speaking as one team.” In that sense, it is a bright spot in U.S. politics as of late and returns to a more normal pattern in U.S. foreign policy where there has been cooperation between outgoing and incoming administrations.

It is unusual that Steve Witkoff, Trump’s designated Middle East special envoy, went on his own to meet with Netanyahu in January and reportedly influenced Netanyahu’s decision to accept a deal that he previously rejected. Many special envoys require confirmation by the Senate, though they can hold the post temporarily without it. They also need security clearances, so that limits some of the things they can do.

What else is notable about the US role in the deal?

It is striking that for all his efforts, Biden seemed to have so little influence on Netanyahu. This has been very difficult for Biden politically. He wanted to get a ceasefire deal done, but he also wanted to stop the suffering in Gaza and didn’t want to look like he was giving Israel a blank check to do whatever it wanted.

In the process, the U.S. has been labeled as partially responsible for the tens of thousands of Palestinian deaths, which some people would call a genocide. This has done a lot of damage to the United States’ global reputation, and that will take some time to repair.

Trump is entirely unpredictable. He may continue to pressure Netanyahu or he may decide that Netanyahu can do whatever he wants.

Three young men are seen waving their hands and clapping and smiling at nighttime.
Palestinians celebrate the announcement of a ceasefire deal between Israel and Hamas in Khan Yunis on Jan. 15, 2025.
Abed Rahim Khatib/Anadolu via Getty Images

What does this deal tell us about the standing of the US in the Middle East?

In some ways, I think it shows the United States’ diminished influence on the Middle East. On the other hand, the geopolitics of other regional conflicts and political changes, like the fall of the Assad government in Syria and the weakening of Hezbollah and Iran over the past year or so, have given certain opportunities to Israel, and therefore the U.S. This includes continuing the Abraham Accords, an agreement the Trump administration helped negotiate in 2020 to normalize relations between Saudi Arabia and Israel.

The Saudis have been clear that they won’t make an agreement with Israel if there is not a state or something else designated for the Palestinians. It may turn out that this current deal, if implemented, offers enough for the Palestinians for the Saudis to also make an agreement with Israel.The Conversation

Gregory F. Treverton, Professor of Practice in International Relations, USC Dornsife College of Letters, Arts and Sciences

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How constitutional guardrails have always contained presidential ambitions

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theconversation.com – Victor Menaldo, Professor of Political Science, Co-founder of the Political Economy Forum, University of Washington – 2025-01-16 13:48:00

Since the U.S. Congress first met in 1789, it has been a key check on the power of the president.
Allyn Cox, via Architect of the Capitol

Victor Menaldo, University of Washington

As Donald Trump’s second inauguration fast approaches, concerns he threatens American democracy are rising yet again. Some warnings have cited Trump’s authoritarian rhetoric, willingness to undermine or malign institutions meant to constrain any president, and a combative style that strives to stretch executive power as far as possible.

Authoritarianism erodes property rights and the rule of law, so financial markets typically respond with alarm to political unrest. If major investors and corporations really believed the United States was on the brink of dictatorship, there would be large-scale capital flight, equity sell-offs, spikes in U.S. credit default swaps or rising bond yields unexplained by typical macroeconomic factors such as inflation forecasts.

Instead, there have been no systematic signs of such market reactions, nor an investor exodus from American markets. Quite the contrary.

This absence of alarm is not conclusive proof that democracy is safe forever, nor that Trump cannot damage American democracy at all. But it does suggest that credible institutions and investors who literally bet on political outcomes for a living do not view an American autocracy as imminent or even likely.

This is probably because the mechanics of upending American democracy would entail surmounting a thick tangle of constitutional, bureaucratic, legal and political obstacles. As a political economist who has written widely about the constitutional foundations of modern democracies, I submit it’s far more complicated than one man issuing brash executive orders.

A group of formally dressed men gather around a small table with a piece of paper on it.
The first reading of the Emancipation Proclamation to the Cabinet marked a moment of a president seizing significant power.
VCG Wilson/Corbis via Getty Images

Presidents have long seized more power

Throughout American history, presidents have achieved far greater expansions of executive power than Trump did in his first term.

Abraham Lincoln suspended habeas corpus during the Civil War, allowing detention without trial. He bypassed Congress through sweeping executive actions, most notably the Emancipation Proclamation, which declared freedom for enslaved people in Confederate states.

Woodrow Wilson created administrative agencies and imposed draconian censorship during World War I via the Espionage Act of 1917 and the Sedition Act of 1918.

Franklin D. Roosevelt’s court-packing plan failed to pass, but it still cowed the Supreme Court into deference. His New Deal bureaucracy centralized vast powers in the executive branch.

Lyndon B. Johnson obtained the Gulf of Tonkin Resolution, transferring major war-making powers from Congress to the presidency. Richard Nixon invoked executive privilege and ordered secret bombings in Cambodia, steps that largely bypassed congressional oversight.

George W. Bush expanded executive prerogatives after 9/11 with warrantless wiretapping and indefinite detention. Barack Obama faced criticism for the dubious legal rationale behind drone strikes targeting U.S. citizens deemed enemy combatants abroad.

These historical examples should not be conflated with an actual ability to impose one-man rule, though. The United States, whatever its imperfections, has a deeply layered system of checks and balances that has repeatedly stymied presidents of both parties when they tried to govern by decree.

Trump’s openly combative style was in many ways less adept at entrenching presidential power than many of his predecessors. During his first term, he broadcast his intentions so transparently that it galvanized numerous institutional forcesjudges, bureaucrats, state officials, inspectors general – to resist his attempts. While Trump’s rhetoric was more incendiary, other presidents achieved deeper expansions of the executive branch more discreetly.

A man stands in front of a U.S. flag holding a piece of paper.
Then-Vice President Mike Pence presides over the certification of the results of the 2020 presidential election on Jan. 6, 2021.
Saul Loeb/POOL/AFP via Getty Images

Trump’s Jan. 6 plan was never realistic

Trump’s failure to impose his will became particularly evident on Jan. 6, 2021, when claims that an “auto-coup” was afoot never translated into the real-world mechanics that would have kept him in office beyond the end of his term.

Even before the Electoral Count Reform Act made the process clearer in 2022, scholars agreed that under the 12th Amendment the vice president’s role in certifying the election is purely ministerial, giving him no constitutional basis to replace or discard certified electoral votes. Similarly, state laws mandate that certification is a mandatory, ministerial duty, preventing officials from arbitrarily refusing to certify election results.

Had Pence refused to certify the Electoral College vote count, it is more likely than not that courts would have swiftly ordered Congress to proceed. Moreover, the 20th Amendment fixed noon on Jan. 20 as the end of the outgoing president’s term, making it impossible for Trump to remain in power just by creating delay or confusion.

The idea that Pence’s refusal to certify could erase state-certified votes, or coerce Congress into accepting alternate slates, had no firm grounding in law or precedent. After Jan. 20, the outgoing president would simply cease to hold office. Thus, the chain of events needed for an auto-coup to occur in 2021 would have fallen apart under the weight of well-established procedures.

A massive bureaucracy

Potential avenues of power consolidation during Trump’s impending second term are equally narrow. The federal bureaucracy makes it exceedingly difficult for a president to rule by fiat.

The Department of Justice alone comprises roughly 115,000 employees, including over 10,000 attorneys and 13,000 FBI agents, most of them career civil servants protected by the Civil Service Reform Act and whistleblower laws. They have their own professional standards and can challenge or reveal political interference. If an administration tries to remove them en masse, it runs into protracted appeals processes, legal constraints, the need to conduct a bevy of lengthy background checks and a crippling loss of institutional knowledge.

Past episodes, including the George W. Bush administration’s politically motivated dismissals of U.S. attorneys in 2006 and 2007, illustrate that congressional oversight and internal department practices can still produce major pushback, resignations and scandals that thwart political interference with the Justice Department.

Independent regulatory agencies also resist being dominated by the president. Many are designed so that no more than three out of five commissioners can belong to the same political party, ensuring some measure of bipartisan representation. Minority commissioners can deploy a host of procedural tools – delaying votes, demanding comprehensive studies, calling for hearings – that slow down or block controversial proposals. This makes it harder for a single leader to unilaterally impose policy. Those minority commissioners can also alert the media and Congress to questionable moves, inviting investigations or public scrutiny.

In addition, a 2024 Supreme Court ruling shifted the power to interpret federal laws, as passed by Congress, away from executive branch government agencies. Now, federal judges play a more active role in determining what Congress’ words mean. This requires agencies to operate within narrower bounds and to produce stronger evidence to justify their decisions. In practical terms, an administration now has less leeway to stretch statutes for partisan or authoritarian ends without encountering judicial pushback.

A group of nine people wearing black robes pose for a portrait.
Federal judges have more power to interpret Congress’ intention than in recent years.
U.S. Supreme Court

Layers of defenses

American democracy has vulnerabilities, and other democracies have collapsed under powerful executives before. But in my view, it’s not reasonable to draw definitive lessons from a tiny number of extreme outliers, such as Hitler in 1933 or the handful of elected leaders who staged more recent auto-coups in fragile or developing democracies such as Argentina, Peru, Turkey and even Hungary.

The United States stands out for having a complex federal system, entrenched legal practices and multiple layers of institutional friction. Those protections have historically proven adept at limiting presidential overreach – whether subtle or bombastic.

In addition, state-level politicians, including attorneys general and governors, have repeatedly demonstrated their willingness to challenge federal overreach through litigation and noncooperation.

The military’s professional culture of civilian control and constitutional fidelity, consistently upheld by the courts, provides another safeguard. For instance, in 1952 the Supreme Court ruling in Youngstown Sheet and Tube Co. v. Sawyer reversed President Harry Truman’s order that the military seize privately owned steel mills to ensure supply during the Korean War.

All those institutional checks are further buttressed by a robust civil society that can mobilize legal challenges, advocacy campaigns and grassroots resistance. Corporations can wield economic influence through public statements, campaign funding decisions and policy stances – as many did in the aftermath of Jan. 6.

Taken together, these overlapping layers of resistance make the path to autocracy far more challenging than many casual observers might assume. These protections also may explain why most Americans are resigned to Trump’s second term: Many may have come to realize that the nation’s democratic experiment is not at stake – and probably never was.The Conversation

Victor Menaldo, Professor of Political Science, Co-founder of the Political Economy Forum, University of Washington

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MLK’s ‘beloved community’ has inspired social justice work for decades − what did he mean?

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theconversation.com – Jason Oliver Evans, Research Associate and Lecturer, University of Virginia – 2025-01-16 12:55:00

Volunteers paint columns in a hallway during the Martin Luther King Jr. National Day of Service at Ron Brown College Preparatory High School in Washington, D.C., in 2019.
Katherine Frey/The Washington Post via Getty Images

Jason Oliver Evans, University of Virginia

Since 1983, when President Ronald Reagan signed Martin Luther King Jr. Day into law, many Americans have observed the federal holiday to commemorate the life and legacy of the civil rights leader, Baptist minister and theologian.

MLK Day volunteers typically perform community service that continues King’s fight to end racial discrimination and economic injustice – to build the “beloved community,” as he often said.

King does not fully explain the phrase’s meaning in his published writings, speeches and sermons. Scholars Rufus Burrow Jr. and Lewis V. Baldwin, however, argue that the beloved community is King’s principal ethical goal, guiding the struggle against what he called the “three evils of American society”: racism, economic exploitation and militarism.

As a Baptist minister and theologian myself, I believe it is important to understand the origins of the concept of the beloved community, how King understood it and how he worked to make it a reality.

Older origins

Although King popularized the beloved community, the phrase has roots in the thought of 19th-century American religious philosopher Josiah Royce.

In 1913, toward the end of his long career, Royce published “The Problem of Christianity.” The book compiles lectures on the Christian religion, including the idea of the church and its mission, and coined the term beloved community. Based on his readings of the biblical gospels, as well as the writings of the apostle Paul, Royce argued that the beloved community was one where individuals are transformed by God’s love.

A black and white portrait of a man in a dark suit jacket and black bow tie.
Philosopher Josiah Royce (1855-1916).
The Royce Society via Wikimedia Commons

In turn, members express that love as loyalty toward each other – for example, the devoted love a member of the church would have toward the church as a whole.

While Royce often identified the beloved community with the church, he extends the concept beyond the walls of Christianity. In any type of community, Royce argued, from clans to nations, there are individuals who express love and devotion not only to their own community, but who foster a sense of the community that includes all humankind.

According to Royce, the ideal or beloved community is a “universal community” – one to which all human beings belong or will eventually belong at the end of time.

‘Beloved’ diversity

Twentieth-century pastor, philosopher, mystic, theologian and civil rights leader Howard Thurman retrieved Royce’s idea of the beloved community and applied it to his life and work, most notably in his 1971 book “The Search for Common Ground.”

Thurman first used the term in an unpublished and undated article: Desegregation, Integration, and the Beloved Community. Here, he argued that the beloved community cannot be achieved by sheer will or commanded by force. Rather, it begins with transformation in each person’s “human spirit.” The seeds of the beloved community extend outward into society as each person assumes the responsibility of bringing it to pass.

Thurman envisioned the beloved community as one that exemplifies harmony – harmony enriched by members’ diversity. It is a community wherein people from all racial, national, religious and ethnic backgrounds are respected, and where their human dignity is affirmed. Thurman was convinced that beloved community was achievable because of the dedication he saw from activists during the struggle for racial integration.

A man in clerical robes photographed sitting off-center in the frame, against a white wall.
Minister, theologian and civil rights activist Howard Thurman.
On Being/Flickr, CC BY-NC-SA

During his lifetime, Thurman sought to build this beloved community through his activism for racial justice. For example, he co-founded the Church for the Fellowship of All Peoples, an interracial and interfaith community in San Francisco, which he co-pastored from 1943 to 1953.

Thurman’s writings and activism deeply influenced King. Burrow argued that it is not entirely clear when and where King first learned the concept of beloved community. Yet King emphasized its importance in much of his writing and political action.

Love and action

In simplest terms, King defined the beloved community as a community transformed by love. Like Royce, he drew his understanding of love from the Bible’s New Testament. In the original Greek, the Gospels use the word “agape,” which suggests God’s self-giving, unconditional love for humanity – and, by extension, human beings’ self-giving, unconditional love for each other.

According to Baldwin, however, King’s understanding of the beloved community is better understood against the backdrop of the Black church tradition. Raised in the Ebenezer Baptist Church of Atlanta, King learned lessons on the meaning of love from his parents, Rev. Martin Luther King Sr. – Ebenezer’s pastor, who was also a leader in the local chapter of the National Association for the Advancement of Colored People – and Alberta Christine Williams King.

One of the distinctions in King’s thought is that he believed the beloved community could be achieved through nonviolent direct action, such as sit-ins, marches and boycotts. In part, he was inspired by Thurman, who had embraced the nonviolence at the heart of Mahatma Gandhi’s resistance against the British in India. For King, nonviolence was the only viable means for achieving the United States of America’s redemption from the sin of racial segregation and white supremacy.

A crowd of people walking in lines march in suits and ties, with one participant holding an American flag.
Martin Luther King Jr. and his wife, Coretta, lead a five-day march to the Alabama State Capitol in Montgomery in 1965.
Bettmann via Getty Images

For King, therefore, the beloved community was not merely a utopian vision of the future. He envisioned it as an obtainable ethical goal that all human beings must work collectively toward achieving.

“Only a refusal to hate or kill can put an end to the chain of violence in the world and lead us toward a community where men can live together without fear,” King wrote in 1966. “Our goal is to create a beloved community and this will require a qualitative change in our souls as well as a quantitative change in our lives.”

Searching for the beloved community today

King’s idea of the beloved community has not only influenced people affiliated with the Christian tradition but also people from other faiths and none.

For instance, scholars Elizabeth A. Johnson, bell hooks and Joy James have reflected upon the meaning of the beloved community amid ongoing challenges such as global climate change, sexism, racism and other forms of structural violence.

People around the world continue to draw insight and inspiration from King’s thought, especially from his insistence that love is “the most durable power” to change the world for the better. Questions remain about whether his beloved community can be realized, or how. But I believe it is important to understand King’s ethical concept and its continuing influence on movements that seek an end to injustice.The Conversation

Jason Oliver Evans, Research Associate and Lecturer, University of Virginia

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