Promoting Global Democracy: Can and Should the United States Continue to Play a Role?

An online annotation by Hannah Colter, Staff Editor

PDF version available here.

I. Introduction

January 6, 2021 marked a dark and fearful day for global democracy, when the United States faced a coup attempt upon its Capitol. This siege not only struck the oldest existing democracy in the world, but also dealt a blow to the pro-democracy movement, both within the United States and around the world. Authoritarianism is on the rise around the world and pro-democracy supporters and activists no longer view the United States as an ideal system of government for freedom and opportunity. With a new administration working to unite America and rectify the previous administration’s alienation of America’s allies and embrace of its enemies, the world faces the question: Should the United States of America play a role in ensuring democracy outside its borders? In this annotation, I will argue that the United States should have a role in ensuring global democracy, but must take measures to internally stabilize its own democracy and rectify its international alliances and reputation in order for America’s influence in promoting democracy to be effective and valuable.

The remainder of this annotation proceeds as follows: Section II will detail the global decline of democracy over the past two decades and the rapid rise of authoritarianism. Section III will discuss the erosion of American democracy and how that erosion has diminished the country’s role in ensuring global democracy and further allowed authoritarianism to flourish. Finally, Section IV will argue that America remains an important actor in promoting global democracy and should play a role in ensuring its survival and growth around the world. However, Section IV will suggest that the only way for the United States to be an effective, respected, and legitimate international proponent of global democracy is by implementing domestic laws, policies, and actions to stabilize and improve its own democracy, repairing international relationships, and recommitting to the international ideals of its democratic allies abroad.

II. The Global Decline in Democracy

Democracy, often thought of as the pillar of freedom and liberty, has been subject to a global assault for most of the twenty-first century, resulting in the erosion of basic democratic values all over the world.^[1] According to Freedom House, global democracy has declined for fourteen consecutive years and the “effects are evident not just in authoritarian states . . . but also in countries with a long track record of upholding basic rights and freedoms.”^[2] Between 2018 and 2019, “individuals in 64 countries experienced deterioration in their political rights and civil liberties while those in just 37 experienced improvements.”^[3] For the first time since 2001, the majority of the global population (54%) lives in autocracies and, since 2009, the percentage of the global population living in autocratizing countries has increased from 6% to 34%.^[4] While numerous factors have contributed to this steady erosion of democracy, the reality remains the same – if authoritarianism continues to outpace and overwhelm democracy and democratic ideals, the freedoms and liberties of people around the globe face extinction.^[5] The effects of diminished liberties have been disproportionately felt by minority groups, who rarely experience equal treatment under the law even in established democracies. Further decline in democratic ideals threatens to subject these groups to yet more unequal treatment and force them to bear the “brunt of government abuses in both democracies and authoritarian states.”^[6] One of the greatest challenges facing democracy is the gross embrace of authoritarianism by leaders of historic democracies including Australia, Italy, and the United Kingdom.^[7] However, nowhere has the dilution of democracy caused more concern than in the United States, which has undergone an unprecedented internal attack on its democratic institutions from the Republican Party and the Trump Administration. The result has been the rapid repeal of democratic policies and deterioration of the United States’ reputation as one of the longest-standing and most-respected examples of democracy around the world.

III. America’s Democracy Under Threat

For much of the world, January 6, 2021 marked a violent, unprecedented attempt by white supremacists and alt-right supporters to undermine democracy on America soil. However, the coup attempt at the United States Capitol represented the culmination of five years of American politicians embracing authoritarian regimes and anti-democratic rhetoric and ideologies.

Since the adoption of the United States Constitution in 1788, the United States has stood as a model of democracy. Granted, America has often failed to live up to its own democratic ideals, plagued since its founding by the oppression of various racial, ethnic, religious, gender, and sexual orientation groups. Nonetheless, the United States has consistently maintained free and fair elections (albeit with significant voter suppression of minority communities), peaceful transfers of power, strong protections of free speech, and clear checks and balances that limit executive power.^[8] With the aggressive rise in authoritarianism worldwide, America’s commitment to preserving and improving these cornerstones of democratic governance, to cooperation between democracies, and to stemming the rise authoritarian regimes remains vital to protecting and expanding liberty and freedom globally.

Out of step with much of the foreign policy of the United States for decades and against the interests of safeguarding democracy, the Trump Administration brazenly embraced authoritarian leaders around the globe while distancing America from its many democratic allies. During his term, President Trump embraced North Korean dictator Kim Jong Un, calling him someone he “respect[s]” and “fell in love [with],” stated that Turkish President Recep Tayyip Erdogan is “doing a very good job,” and praised Russian President Vladimir Putin as “really very much of a leader.”^[9] Beyond these verbal affirmations, the Trump Administration refused to condemn and hold accountable dictators and authoritarian regimes for interference with the democratic processes of foreign states and for human rights violations. For instance, the Trump Administration refused to impose sanctions on Russia for the country’s interference in the United States’ 2016 election and “protect[ed] Saudi Crown Prince Mohammed Bin Salman from Congressional retaliation after the killing of . . . [reporter] Jamal Khashoggi.”^[10] The flowery words and lack of action from the President of the United States legitimized the actions of authoritarian leaders around the world. The President’s behavior constituted a strike against established democratic cultures and degraded the power of pro-democracy forces who monitor and enforce human rights and democracy around the world.^[11]  

The Trump Administration and the Republican Party not only embraced authoritarian leaders, but also adopted authoritarian rhetoric and ideologies within the United States. For the duration of his presidency, Donald Trump and the Republican Party invoked many of the same tactics used by authoritarian regimes in other countries to gain and maintain control. For instance, authoritarians commonly reject facts and spread lies to manipulate the public.^[12] During his four years in office, President Trump made over 30,000 false or misleading claims.^[13] These claims ran the gambit, including lies about U.S. Congress members supporting international terrorist organizations, false representations of President Biden’s stances on various policies, and serious understatements of the danger posed by the Coronavirus.^[14] President Trump also undermined the security of the United States by siding with foreign adversaries over the United States intelligence community on numerous occasions, such as when Russia reportedly placed bounties on the heads of U.S. soldiers.^[15] The most blatant and alarming authoritarian act came when President Trump spread patently false claims about the validity of the 2020 presidential election, after which he refused to concede and move forward with a peaceful transfer of power. In the lead-up to the election, President Trump and Republican politicians made numerous claims that mail-in voting would be “substantially fraudulent” and would lead to the most corrupt election in United States history.^[16]> They asserted these claims despite overwhelming evidence that voting by mail, and voting in the United States generally, results in almost no fraud.^[17] This attempt to undermine public confidence in the presidential election extended well past election day, when President Trump refused to concede the presidential election to President Biden despite the latter reaching the necessary threshold in the Electoral College race and receiving 81,283,098 votes, over seven million more than President Trump.^[18] While the outcome of the election is clear, President Trump and the Republican Party continue to peddle false information about the outcome of the election, with President Trump claiming over 100 times that the election was “rigged” or “stolen” between election day and January 6, 2021, and 147 Republican members of Congress formally objecting to the election results despite the lack of evidence of voter fraud or of a rigged election.^[19]

The refusal by Republican political leaders to commit to a peaceful transfer of power, a unique characteristic of American democracy and one respected by countries and international leaders around the world,^[20] culminated in the coup attempt on the United States Capitol on January 6, 2021, when a mob of Trump supporters descended upon the Capitol with the intention of stopping the certification of the election results by Congress and harming Democrat political leaders.^[21] President Trump and congressional members of the Republican Party directly incited the riot at the Capitol with their repeated, untrue claims of a stolen election, their dog whistle language used to summon supporters to the Capitol on January 6, constant calls to “fight for America,” and direct instructions to march down to the Capitol.^[22] These actions are reminiscent of the tactics and rhetoric used by dictators around the world for decades.^[23] January 6 marked a day when America’s once-admired version of democracy fell to a years-long authoritarian campaign and cemented the rapid fall in international reputation and leadership that the United States had been experienced for the previous four years.

IV. America’s Role in Ensuring Global Democracy

Historically, the United States has generally rejected authoritarianism and totalitarianism and has acted as an enforcer of democracy and freedom around the globe.^[24] The United States is one of many western democracies that has “aggressively invested in pro-democracy programming, strengthening civil society, political parties and the rule of law in countries across the world in an attempt to erect barriers against authoritarianism.”^[25] However, the coup attempt at the Capitol signaled the dramatic shift in U.S. politics, away from those democratic ideals and from the pro-democracy influence that the United States has held since its founding. Those values and that influence waned under the Trump Administration. Following the coup attempt, the world has been left to wonder, what will be the role of the United States in monitoring, encouraging, and enforcing democratic freedoms and liberties abroad?

In order to determine the United States’ role in ensuring democracy globally, one must first determine the international community’s opinion of the United States and its democracy. As was discussed above, the United States’ political influence had severely diminished during the Trump Administration, due to that Administration’s embrace of long-time geopolitical adversaries of the United States, such as Russia and North Korea, and to its consistent erosion of America’s long-standing allyships with countries such as Germany and France.^[26] This distortion of historic foreign relations policy has caused the United States to lose a significant amount of its power and influence in the coalition of democratic states working against authoritarianism and the degradation of fundamental rights and freedoms.^[27] Furthermore, the United States’ domestic political landscape, which has seen a significant increase in authoritarian rhetoric and ideology, has drastically undermined the country’s reputation as a democratic ideal.

At no point has America’s reputational decline been on greater display than in the international reaction to the coup attempt on January 6, 2021. As the world watched in shock, many countries expressed their dismay at the democratic erosion that had occurred in the United States, calling the riot “disgraceful,” “a deliberate assault on democracy by a sitting President,” and “utterly horrifying.”^[28] This condemnation by allies in regard to America’s democratic process offers a stark representation of America’s decline in international esteem. Even more alarming, however, were the reactions of totalitarian and authoritarian regimes and America’s geopolitical rivals to the United States Capitol siege.  Iran’s President Rouhani claimed the riot “showed the failure and frailty of Western democracy in the world,” while Russia declared “[t]he holiday of democracy is over” and that “America no longer charts the course.”^[29] Even more damning, Zimbabwe’s President Mnangagwa exclaimed that the riots “showed that the U.S. has no moral right to punish another nation under the guise of upholding democracy.”^[30] The Capitol riots did more than just tarnish the democratic processes of the United States; these riots served to cripple the United States’ credibility as an international superpower that reveres, protects, and enforces democratic processes and institutions around the world. American allies’ distrust of the Unites States due to its recent embrace of dictators and authoritarian ideals, along with the public viewing of the progressive deterioration of the world’s oldest democracy, has left America at perhaps its lowest point of international influence since emerging as a global superpower.

With authoritarianism on the rise worldwide and democratic rule declining, the loss of American leadership could prove detrimental for global freedom and liberty. It is unarguable that American pressure has, in the past, proved instrumental in ensuring free and fair elections, the respect of human rights, and preventing the rise of dictatorships (albeit with a consistent undertone of hypocrisy at America’s failing to live up to these ideals itself).^[31] So again, it must be asked, what role should America play in enforcing global democracy, in the shadow of four years of egregious foreign and domestic policy that culminated in a coup attempt against its own democratic institutions?

The election of Joe Biden signals the return of an America that, at least publicly, embraces democracy and rebukes tyrannical leaders and authoritarian regimes. Yet, despite President Biden’s commitment to “reclaiming [America’s] credibility and moral authority,” beginning with his work to “strengthen [America’s] alliances,” America’s hypocrisy as an advocate for democratic government has been put on full and dramatic display and regaining its credibility in this area when its democracy is already in decline will be a tall order, but one that must be filled.^[32] America should have a place in ensuring global democracy, and that can only occur by restoring American credibility and commitment to democratic ideas and actions.

In order to reestablish its democratic credibility, the United States will have to repair, first and foremost, the significant fractures to its own democracy that were exposed and worsened during the Trump Administration. America’s reputation has been so eroded that foreign states will not likely accept criticism from and interference by the United States as legitimate so long as America’s own democracy falters. There are therefore numerous actions that must be taken by the Biden Administration and American political leaders to improve America’s democracy. First, Congress and President Biden must pass and sign into law the John Lewis Voting Rights Act and the For the People Act, which promise to be the most significant pro-democracy legislation passed in the United States in decades.^[33] Together, these bills seek to ensure equal and indiscriminate voting access, to simplify the voting process by removing many Jim Crow voting relics still utilized by Republicans to prevent minority groups from voting, to restore many protections against racial discrimination and intimidation that were gutted from the Voting Rights Act of 1965, and to create punishments for voter intimidation and promotion of false information about voting rights.^[34] Second, the Biden Administration must increase transparency and openness in governance. It could accomplish this by ending the Trump Administration practice of making false or misleading comments about administration policy or general facts, filling the many vacancies left open at independent agencies, ceasing presidential or other political interference in the operation of those agencies, and by directing agencies to cooperate with Freedom of Information Act requests and independent oversight organizations.^[35] Finally, effective policies must be implemented to address the significant gender, race, religious, and sexual-orientation discrimination that many government institutions promote, for example in housing or education policy. An overhaul of the policing, housing, education, and medical systems is key in improving the unequal treatment faced by many minority groups. Additionally, policies and practices that work to address the gender pay gap and the wealth gap in America are instrumental to improving American democracy. All of these areas have been identified by Freedom House as pressure points for the erosion of American democracy over the last decade, therefore must be fixed to stabilize American democracy.^[36]

Furthermore, America has the immense task of reestablishing its reputation as a frequent  force against authoritarianism. This must be done by rebuilding America’s alliances with pro-democracy nations and working together with those nations to stem the tide of totalitarianism. The Biden Administration could do this by emphasizing the United States’ commitment to the Paris Climate Accord and to the World Health Organization. Additionally, many foreign policy decisions of the Trump Administration must be rectified, such as repealing the “Muslim Ban” travel restrictions, restoring Temporary Protected Status immigration designations, entering into a new nuclear deal with Iran, and issuing sanctions against countries like Russia who have interfered in American democracy. All of these actions would work to signify America’s deep commitments to our shared ideals and partnerships with allies and to ensuring freedom, liberty, democracy around the world.  If America begins rebuilding its democracy internally and repairs relationships with its democratic allies, the United States can begin working more effectively and legitimately to protect and promote democracy around the world.

V. Conclusion

In order to curb the rise of authoritarianism around the world and reestablish democracy as the ideal system of government, the United States must play a role in ensuring freedom and liberty in foreign nations. However, the past four years of governance by the Trump Administration have eroded American leadership and credibility, torn the fabric of democracy domestically and internationally, and put on display the long-existing hypocrisies of America’s attempts at enforcing democratic freedoms abroad. The United States must reclaim its power as an international proponent of democratic principles and once again direct that power toward ensuring freedom, fair elections, democracy, and individualism. This will only happen once America begins to repair its democracy at home.

[1] Varieties of Democracy Institute, Democracy Report 2020: Autocratization Surges – Resistance Grows (2020), https://www.v-dem.net/media/filer_public/de/39/de39af54-0bc5-4421-89ae-fb20dcc53dba/democracy_report.pdf (discussing how majority of the global population live under autocratic rule and “government assaults on civil society, freedom of expression, and the media are proliferating and becoming more severe.”).

[2] Press Release, Freedom House, New Report: Freedom in the World 2020 Finds Established Democracies are in Decline (Mar. 4, 2020) (on file with author), https://freedomhouse.org/article/new-report-freedom-world-2020-finds-established-democracies-are-decline (Using methodology derived from the Universal Declaration of Human Rights, the study analyzes political rights and civil liberties to track global democracy. Twenty-five indicators are used to score 198 countries and 15 territories out of 100, with a score of 100 being perfectly free and 0 being freedom, and classifies each country as Free, Partly Free, or Not Free).

[3] Id.

[4] Varieties of Democracy Institute, supra note 1.

[5] Id.; Ari Shapiro, How Trump’s Embrace of Authoritarian Rules Has Impacted the World, NPR (May 14, 2019), https://www.npr.org/2019/05/14/723325835/how-trumps-embrace-of-authoritarian-rulers-has-impacted-the-world.

[6] Freedom House, supra note 2.

[7] Europe and Right-Wing Nationalism: A Country-By-Country Guide, BBC (Nov. 13, 2019),  https://www.bbc.com/news/world-europe-36130006.

[8] Claire Cain Miller & Kevin Quealy, Democracy in America: How Is It Doing?, N.Y. Times (Feb. 23, 2017), https://www.nytimes.com/2017/02/23/upshot/democracy-in-america-how-is-it-doing.html.

[9] Chris Cillizza & Brenna Williams, 15 Times Donald Trump Praised Authoritarian Rulers, CNN, https://www.cnn.com/2019/07/02/politics/donald-trump-dictators-kim-jong-un-vladimir-putin (last updated July 2, 2019, 1:33 PM); Domenico Montanaro, 6 Strongmen Trump Has Praised – and the Conflicts It Presents, NPR (May 2, 2017), https://www.npr.org/2017/05/02/526520042/6-strongmen-trumps-praised-and-the-conflicts-it-presents.

[10] Andrew Solender, Trump Reportedly Boasted About ‘Saving’ Saudi Crown Prince After Khashoggi Killing, Forbes (Sep. 10, 2020, 2:21 PM), https://www.forbes.com/sites/andrewsolender/2020/09/10/trump-reportedly-boasted-about-saving-saudi-crown-prince-after-khashoggi-killing/?sh=6f7644ec5c9b.

[11] Shapiro, supra note 2.

[12] Casey Michel, Spreading Lies Is a  Classic Authoritarian Power Move. Don’t Let Trump Get Away with It, Quartz (Feb. 10, 2017), https://qz.com/907097/spreading-lies-is-a-classic-authoritarian-power-move-dont-let-trump-get-away-with-it/.

[13] In Four Years, President Trump Made 30,573 False or Misleading Claims, Washington Post,  https://www.washingtonpost.com/graphics/politics/trump-claims-database/?itid=lk_inline_manual_4 (last updated Jan. 20, 2021).

[14] Daniel Dale, The 15 Most Notable Lies of Donald Trump’s Presidency, CNN,  https://www.cnn.com/2021/01/16/politics/fact-check-dale-top-15-donald-trump-lies/index.html (last updated Jan. 16, 2021, 9:28 AM).

[15] Quint Forgey, ‘A Lot of People Said It’s a Fake Issue’: Trump Confirms He Didn’t Raise Russian Bounties with Putin, Politico, https://www.politico.com/news/2020/07/29/trump-russian-bounties-putin-call-385925 (last updated July 29, 2020, 8:32 AM).

[16] https://link.springer.com/article/10.1007/s12115-020-00526-y; RNC 2020: Trump Warns Republican Convention of ‘Rigged Election’, BBC (Aug. 25, 2020), https://www.bbc.com/news/election-us-2020-53898142.

[17] Debunking the Voter Fraud Myth, Brennan Center for Justice (Jan. 31, 2017),  https://www.brennancenter.org/our-work/research-reports/debunking-voter-fraud-myth.

[18] James M. Lindsay, The 2020 Election by the Numbers, Council on Foreign Relations (Dec. 15, 2020, 7:00 AM), https://www.cfr.org/blog/2020-election-numbers.

[19] Hayley Miller, Trump Claimed Election’Rigged’ or ‘Stolen’ Over 100 Times Ahead of Capitol Riot, HuffPost, https://www.huffpost.com/entry/trump-rigged-stolen-capitol-riot_n_602188e2c5b6173dd2f88c4f (last updated Feb. 9, 2021); Li Zhou, 147 Republican Lawmakers Still Objected To The Election Results After The Capitol Attack, Vox,https://www.vox.com/2021/1/6/22218058/republicans-objections-election-results (last updated Jan. 7, 2021, 3:28 PM).

[20] See, e.g., Top UN Officials Saddened At Mob Violence During US Capitol Breach; Bachelet Decries ‘Incitement’ By Political Leaders, UN News (Jan. 7, 2021), https://news.un.org/en/story/2021/01/1081542 (The Inter-Parliamentary Union called the United States a “bastion of democracy,” and the President of the UN General Assembly called the United States “one of the world’s major democracies.”); Mark Hannah & Caroline Gray, Global Views of American Democracy: Implications for Coronavirus and Beyond (2020), https://egfound.org/wp-content/uploads/2020/03/Global-Views-of-American-Democracy-EGF.pdf (reports that, generally, individuals in other countries like American democracy twice as often as they dislike it, and provides top reasons why American democracy is likeable); Valentina Pop & Ryan Dube, World Leaders Are Shocked, Worried by Trump Supporters’ Actions at U.S. Capitol, Wall St. J., https://www.wsj.com/articles/world-leaders-are-shocked-worried-by-storming-of-u-s-capitol-by-trump-supporters-11609971098 (last updated Jan. 7 2021, 5:40 AM) (Boris Johnson said “[t]he United States stands for democracy around the world…”).

[21] David A. Graham, We’re Just Finding Out How Bad the Riot Really Was, Atlantic (Jan. 16, 2021), https://www.theatlantic.com/ideas/archive/2021/01/it-was-much-worse-it-looked/617693/.

[22] Catie Edmondson & Luke Broadwater, Before Capitol Riot, Republican Lawmakers Fanned the Flames, N.Y. Times, https://www.nytimes.com/2021/01/11/us/politics/republicans-capitol-riot.html (last updated Jan. 29, 2021).

[23] Amanda Taub, Donald Trump’s Tactics are Disturbingly Similar to Those of Actual Dictators, Vox (Mar. 21, 2016), https://www.vox.com/2016/3/21/11275978/trump-dictator-tactics (makes comparisons of Trump’s words and actions to dictators around the world); John Haltiwanger, Historians and Election Experts Warn Trump is Behaving Like Mussolini and Despots That the US Usually Condemns, Business Insider (Sep. 25, 2020), https://www.businessinsider.com/historians-election-experts-warn-trump-behaving-like-mussolini-2020-9.

[24] Catharin E. Dalpino, Promoting Democracy and Human Rights: Lessons of the 1990s, Brookings Inst. (Sep. 1, 2000), https://www.brookings.edu/articles/promoting-democracy-and-human-rights-lessons-of-the-1990s/ (“Before 1989, foreign aid for democratic development seldom topped $100 million a year. By 1993, that figure had climbed to $900 million.”); Marian L. Lawson & Susan B. Epstein, Democracy Promotion: An Objective of U.S. Foreign Assistance  4–8, 12–17 (Congressional Research Service version 5 2019) (discussing U.S. democracy assistance since the Cold War and the allocation of funds to democracy promotion today).

[25] Benjamin Press, American Diplomacy and the Fight Against Authoritarianism, American Ambassadors Live! (Nov. 25, 2020), https://www.americanambassadorslive.org/post/american-diplomacy-and-the-fight-against-authoritarianism.

[26] Tal Axelrod, Here Are the US Allies That Have Been in Trump’s Crosshairs, Hill (Aug. 24, 2019, 12:20 PM),  https://thehill.com/policy/international/458455-here-are-the-us-allies-that-have-been-in-trumps-crosshairs.

[27] Pop & Dube, supra note 20 (the former President of Bolivia called the Capital riots a “profound deterioration of the democratic image of the country,” and one Russia expert declared “The United States will never again be able to tell the world that [the United States is] the paragon of democracy).  

[28] Tucker Reals, Foreign Reaction to the “Disgraceful Scenes” at the U.S. Capitol, CBS News, https://www.cbsnews.com/news/us-capitol-riot-donald-trump-protests-foreign-reaction/ (last updated Jan. 7, 2021, 12:47 PM).

[29] Id.

[30] Id.

[31] See e.g., Mark Logan, The Whys and Hows of Promoting Democracy, Council on Foreign Relations (Feb. 11, 2011), https://www.cfr.org/expert-brief/whys-and-hows-promoting-democracy (discussing the role of the United States in “deepening and widening democracy in Western Europe” after WWII through the formation of NATO); Amenda Shendruk, Laura Hillard & Diana Roy, Funding the United Nations: What Impact Do U.S. Contributions Have on UN Agencies and Programs?, Council on Foreign Relations, https://www.cfr.org/article/funding-united-nations-what-impact-do-us-contributions-have-un-agencies-and-programs (last updated June 8, 2020, 8:00 AM) (noting that the United States is the largest funder of the United Nations, with over $10 billion contributed in 2018, thereby funding many programs that protect and promote matters of peace and democracy, and which are dependent of U.S. funding).

[32] Amanda Macias, Biden Vows To Restore U.S. Alliances And Lead With Diplomacy In His First Foreign Policy Address, CNBC, https://www.cnbc.com/2021/02/04/biden-vows-to-restore-alliances-in-first-foreign-policy-address.html (last updated Feb. 4, 2021, 8:45 PM).

[33] Sylvia Albert, Why Congress Must Pass HR 1 and the John R. Lewis Voting Rights Act, Roll Call (Mar. 2, 2021), https://www.rollcall.com/2021/03/02/why-congress-must-pass-hr-1-and-the-john-r-lewis-voting-rights-act/.

[34] Id.

[35] Freedom House, supra note 2.

[36] Id.