A son died, his parents tried to sue. How U.S. courts protect Big Pharma

[Leroy N. Soetoro]

https://reuters.com/investigates/special-report/usa-lawsuits-merck-
singulair/

Merck’s best-selling asthma medicine, Singulair, has been linked for years
to suicides and psychiatric problems, often in children. But lawsuits over
the drug are stymied by one of Corporate America’s most effective
liability shields: the doctrine of federal preemption.

Nicholas England, a healthy 22-year-old from Virginia, shot himself in the
head in 2017, less than two weeks after he started taking an allergy
medicine that had been linked for years to episodes of depression and
suicidal thinking.

His parents soon started exploring a lawsuit against Merck, the developer
of the blockbuster asthma and allergy drug, Singulair, along with the
manufacturer of the generic version their son took. Nicholas had no
history of mental-health problems, they said.

The Englands were shocked to learn from legal advisers that they had no
case. Like countless other potential plaintiffs, they had run into one of
Corporate America’s most effective liability shields: the legal doctrine
of preemption, the principle that federal law supersedes state law.

Armed with U.S. Supreme Court rulings on preemption starting in the 1990s,
companies increasingly argue that federally regulated products or services
should be immune from lawsuits alleging state-law violations. In a new
reading of an old constitutional principle, judges have held that federal
law, including the decisions of U.S. regulatory agencies, should preempt,
or override, state statutes that seek to hold companies accountable for
harming consumers.

State laws historically have provided the legal basis for some of the most
common lawsuits against U.S. companies alleging injuries, deaths or
illnesses caused by negligence or defective products.

“The emotion of losing your child is so difficult on its own. It is very
frustrating to realize that’s a loophole. I’m a small person in
southwestern Virginia, and that’s a loophole there to protect companies
much bigger than we could fight.”

Jennifer England, whose son died by suicide after taking an allergy
medicine tied to psychiatric problems.
These legal dynamics left the England family with no legal remedy at all.
A pair of U.S. Supreme Court rulings, in 2011 and 2013, essentially barred
lawsuits against generic drugmakers based on state laws that enabled
claims over design defects or a failure to warn consumers of potential
dangers. The court’s reasoning: Such claims were preempted by federal
regulations preventing generic drugmakers, when copying name-brand drugs,
from changing the formulation or the warning label.

That meant Merck had written the warning label, with federal approval, on
the generic version of Singulair that Nicholas England took. But his
parents couldn’t sue Merck, either, because their son had never taken its
name-brand version of Singulair.

“The emotion of losing your child is so difficult on its own,” said
Jennifer England, Nicholas’s mother. “It is very frustrating to realize
that’s a loophole. I’m a small person in southwestern Virginia, and that’s
a loophole there to protect companies much bigger than we could fight.”

Merck declined to comment for this report, referring all questions to
Organon, a Merck spinoff created in 2021 that now markets Singulair.
Organon declined to answer detailed questions from Reuters but said in a
statement that it’s confident doctors and patients have gotten “complete
and appropriate information” on Singulair’s safety. The generic drug
manufacturer that made the pills England took, Teva Pharmaceuticals, did
not respond to inquiries.

Corporate preemption defenses have proved broadly effective, according to
a Reuters analysis of court cases and dozens of interviews with attorneys,
legal scholars and plaintiffs or potential plaintiffs affected by
preemption rulings. The analysis of federal appeals and Supreme Court
rulings involving preemption found that judges ruled two-thirds of the
time to weaken or kill lawsuits alleging deaths or injuries caused by
corporate negligence or defective products.

Preemption defenses often deliver companies a swift procedural win,
allowing them to avoid addressing the substance of plaintiffs’
allegations. It has been used across a range of federally regulated
sectors, from railroads to agricultural chemicals to airlines and
automobiles, the Reuters review found.

The preemption defense has had a particularly profound impact in the
pharmaceutical industry, the review showed. The high court’s ban on
certain lawsuits against generic drug manufacturers has extraordinary
reach because generics account for 91% of U.S. prescriptions, according to
data from the U.S. Food and Drug Administration (FDA).

Name-brand drugmakers can still be sued, but preemption defenses can make
it much harder for plaintiffs to prevail, drug-industry litigation experts
said. In many product-liability cases, plaintiffs must prove simply that a
company’s product was unsafe. Those facing drugmakers’ preemption defenses
must often demonstrate that a company failed to disclose safety
information to federal regulators – and that the information could have
spurred new government restrictions or warnings before the alleged harm
occurred.

Pending lawsuits against Merck allege that the company’s own early
research indicated the drug could impact the brain but that Merck
downplayed any risks in statements to regulators.

England’s family had hoped to force executives from Merck and the generic
manufacturer to reveal what they knew, and when, about the drug’s dangers.
In the decade before England’s death, the FDA received more than 4,800
reports of patients, including many children, experiencing depression,
suicidal thoughts or other psychiatric problems after taking Singulair or
a generic version, according to a Reuters review of FDA data.

But it wasn’t until 2020 that the FDA slapped its most serious warning,
called a “black box,” on the drug’s label. By that time, the FDA had
received more than 80 reports of suicides in people taking the medicine.

Singulair, one of the best-selling drugs in U.S. history, has provided
Merck with about $50 billion in revenue, company disclosures show. Since
Merck’s patent on Singulair expired in 2012, major generic drug
manufacturers have sold millions of prescriptions under the drug’s
scientific name, montelukast.

The FDA said in a statement that it has “diligently monitored reports of
side effects possibly associated with montelukast, as well as communicated
findings and taken regulatory action, when appropriate.” The agency said
it “continues to monitor and investigate this important issue.”

The FDA declined to comment on how modern preemption defenses and court
rulings have impacted pharmaceutical regulation and litigation.

Big Tobacco precedent

The doctrine of preemption is based on the U.S. Constitution’s supremacy
clause. The original intent: to resolve conflicts between federal and
state statutes and discourage state legislatures from passing laws that
undermine federal policy.

Preemption-based corporate defenses are a modern phenomenon. American
courts have historically viewed product-liability lawsuits, largely based
on state laws, as vital to holding companies accountable when federal laws
and regulations fail to do so. Courts recognized drugmaker liability for
harmful medicines as early as the 1850s, according to a Supreme Court
filing. FDA regulations once routinely specified that its decisions had no
impact on drugmakers’ liability.

That started to change in 1992, in a case involving a smoker who died of
cancer. The Supreme Court ruled that federal requirements for cigarette
labels, which had included smoking warnings since the 1960s, overrode some
of her family’s state-law claims that a tobacco company failed to warn her
about smoking hazards.

States ultimately used different theories to force Big Tobacco into a $246
billion settlement. Still, the precedent gave Corporate America a
blueprint for defeating similar lawsuits on preemption grounds.

Corporations got more help in the political arena. U.S. President George
W. Bush had promised in his 2000 campaign to attack what Republicans
derided as frivolous litigation targeting American industry.
Administration officials undertook what critics dubbed “stealth” tort
reform: intervening in lawsuits on the side of corporate defendants, with
the goal of convincing judges to set precedents making it harder to sue
companies.

Bush’s FDA exemplified the tactic. Daniel Troy, the agency’s chief
counsel, interpreted preemption to mean that courts can’t undermine
federal regulators based on alleged state-law violations. He aimed to make
that argument in high-profile lawsuits. At a 2003 conference, Troy invited
an audience of drug-industry lawyers to pitch the FDA on intervening in
their cases.

“We can’t afford to get involved in every case – we have to pick our
shots,” he told the assembled lawyers. “So make it sound like a Hollywood
pitch.”

Troy, now a veteran pharmaceutical industry lawyer himself, said his goal
at the time was simply to defend and strengthen the FDA’s authority to
regulate without interference.

“If you believe in a strong FDA,” he said, “we can’t have state courts,
especially juries, second-guessing and undercutting the FDA’s judgments.”

The FDA formally changed its view of preemption in a 2006 regulation,
stating the agency now believed that FDA labeling approval “preempts
conflicting or contrary State law.”

In its statement to Reuters, the FDA declined to comment on the 2006
regulation or the agency’s current view of preemption.

One of the Bush-era FDA’s biggest victories came in 2008, when the Supreme
Court cited preemption in dismissing a New York man’s lawsuit against
Medtronic over a burst balloon catheter. The precedent has since
effectively barred wide swaths of lawsuits against medical-device
manufacturers.

To examine the impact of preemption defenses, Reuters reviewed 257 federal
appeals and Supreme Court rulings, which are the most influential in
establishing precedents. In the cases, dating back to 2001, the courts
determined whether preemption nullified plaintiffs’ claims that deaths or
injuries were caused by corporate negligence or defective products. Judges
threw out some or all of the claims on preemption grounds in two-thirds of
the cases.

Another industry benefit can’t be quantified: The number of potential
lawsuits that were never filed – like the one over Nicholas England’s
death – because preemption precedents favor corporations, legal experts
said.

Adam Zimmerman, a professor at the University of Southern California’s
Gould School of Law, said the Reuters analysis underscores how these
preemption precedents, which bind lower courts, have delivered
corporations critical courtroom wins and leverage in settlement
negotiations.

“It is really meaningful for the business community,” Zimmerman said.

Jay Lefkowitz, a Kirkland & Ellis partner who has represented companies
before the Supreme Court, called preemption a “firmly enshrined”
constitutional principle. State court juries, he said, shouldn’t be
deciding how drug labels read based on the evidence in one case.

“We want the scientists and doctors at the FDA to do so,” he said, “based
on all of the accumulated data from clinical trials and real world
experience.”

Train wreck

Corporate preemption defenses are now common across a host of federally
regulated industries.

After a February train derailment in East Palestine, Ohio, released toxic
chemicals, train operator Norfolk Southern invoked preemption to counter
pending lawsuits.

Asked about the legal strategy, the company told Reuters it was “following
the legal process” and that it was committed to paying for the
environmental clean-up and any damage to residents’ health, water supply
or property values.

The Reuters analysis found about three dozen examples over the past two
decades of companies in the railroad industry invoking preemption to avoid
liability. They cite federal laws regulating the safety of railroads and
hazardous materials transportation. In 2015, for instance, a Union Pacific
train struck a pickup in Louisiana, killing three people, according to
court records. The truck’s driver was the last in a convoy, waiting to
proceed through a gate that hadn’t yet opened. Seconds later, a Union
Pacific train barreled down the tracks at about 50 miles an hour.

The crash victims’ families sued and lost, in part because the Federal
Railroad Safety Act preempted their claims that a horn sounded by the
conductor failed to adequately warn of the oncoming train. Plaintiffs had
argued that several short horn blasts, for instance, would have been more
effective. An appeals court ruled their case was preempted because federal
regulation defers to an engineer’s “sole judgment” on sounding a horn in
such instances.

Union Pacific said in a statement that the engineer complied with federal
law and that preemption provides a “consistent, uniform law” for train
operators transporting goods across state lines.

In another pharmaceutical case involving suicide, a woman whose husband
threw himself in front of a train shortly after he started taking the
antidepressant paroxetine was barred by preemption from suing the generic
manufacturer. Then, an appeals court cited preemption in overturning a $3
million verdict the woman had won against GlaxoSmithKline, which made the
brand-name version of the drug and controlled its label. The court found
that the FDA would have rejected an adult suicide warning at the time her
husband took it.

GlaxoSmithKline said in a statement that preemption is a “well-established
legal principle grounded in the U.S. Constitution” to address conflicts
between federal and state law. The company said it repeatedly asked the
FDA to add a warning about suicidal thinking in adults to the label but
the agency refused. The FDA instead mandated the same label for all drugs
in the class that included paroxetine, which did not include such a
warning.

Agricultural giant Monsanto is now pinning its hopes on preemption to help
defeat or weaken tens of thousands of legal claims alleging it failed to
warn consumers that its popular weed killer Roundup could cause cancer. In
June, the company, owned by Bayer, urged a federal appeals court in
Atlanta to dismiss one of those cases on preemption grounds, arguing
federal regulators did not require a cancer warning on Roundup’s label.

Bayer said in a statement that these state-based claims are preempted
because federal law expressly forbids states from instituting different
labeling requirements. Federal regulators, Bayer said, have consistently
found that Roundup and similar herbicides can be used safely and are not
carcinogenic.

While preemption precedents favor corporations, judges’ tolerance for the
argument has its limits. The Supreme Court in 2009 rejected the contention
from drugmaker Wyeth, along with industry groups, that FDA approval should
give name-brand drugmakers blanket immunity from certain types of
lawsuits. The court ruled in favor of a Vermont woman who alleged the
firm’s drug Phenegran led to the amputation of her arm.

‘I was poisoning him’

Preemption defenses rely in part on the notion that state laws are not
needed to protect citizens who are already safeguarded by federal
regulators. But in the case of Singulair’s potentially deadly side
effects, the FDA waited years, despite thousands of reported psychiatric
problems, to require its most serious warning on the drug’s label.

By the time Nicholas England killed himself, the FDA had been reviewing
Merck’s disclosures about health risks for nearly two decades. Parents who
argue Singulair endangered their children view the FDA’s 2020 decision to
add a black box warning as vindication, but many still want to sue Merck
for not acting sooner.

In the years after Singulair’s 1998 launch, reports of related
neuropsychiatric episodes piled up on internet forums and in the FDA’s
early-warning detection system. The system compiles reports of “adverse
events” from patients, doctors and others to track potential dangers
discovered after a drug hits the market.

Jan Gilpin’s son was first prescribed Singulair for asthma in 2003, at age
three. The boy soon seemed withdrawn and sullen. He would sometimes go
“into a strange trance, mumbling to himself,” Gilpin wrote in 2008 in a
report to the FDA. “Worst of all, he started talking about death – wanting
to die, wishing he was dead, saying that he hated himself.”

“I realized he hadn’t laughed in two years. I didn’t realize that I was
poisoning him with this medicine.”

Jan Gilpin, whose young son fell into a depression and obsessed about
death after taking Merck’s asthma drug Singulair.
Gilpin didn’t suspect Singulair for more than three years. In 2007, she
stopped giving her son the drug after she stumbled on parents’ online
posts about their children experiencing social anxiety while taking the
medicine.

Soon, she noticed he began to skip and laugh.

“I realized he hadn’t laughed in two years,” said Gilpin, speaking through
tears. “I didn’t realize that I was poisoning him with this medicine.”

The boy’s obsessive thoughts about death disappeared after he quit the
medicine, Gilpin said, but he seemed to have some lingering effects, such
as anxiety, that took longer to go away.

In August 2007, a 15-year-old boy in New York killed himself 17 days after
first taking Singulair. Two months later, Merck proposed, and the FDA
agreed, to amend Singulair’s label to add suicidal thinking and behavior
to a list of adverse events reported to the company.

But the mention of suicidal thinking appeared in the middle of a list of
more than three dozen side effects. Parent advocates argue the new label
was grossly inadequate to warn of such a grave risk.

Three weeks after proposing the label change, Merck asked the FDA about
getting permission to sell Singulair over-the-counter, without a
prescription, for adults with hay fever. The FDA agreed to consider it but
also wanted to understand more about suicide risks. A 2008 FDA review of
the drug’s psychiatric affects and suicide risks recommended “further
studies in animals and humans” and suggested the agency consider asking
Merck to conduct an observational study.

The FDA did not require such a study, reasoning in part that serious side
effects including suicidal thinking “were expected to be quite rare.”

In 2011, the agency rejected a petition from Gilpin and other parents
seeking a black box warning, citing what it called insufficient evidence
that the drug caused suicidal behavior.

82 suicides

After Merck’s patent on Singulair expired in 2012, generic manufacturers
started producing the drug. The number of patients prescribed the medicine
climbed from about 7 million annually to more than 9 million, according to
the FDA. Some years, nearly half of these patients were 16 or younger.

The FDA convened an advisory panel in 2014 to consider Merck’s request to
offer Singulair over-the-counter. At the FDA’s request, Merck had re-
analyzed its Singulair clinical-trial data in 2009. The company had
reported that an 18-year-old trial participant had attempted suicide and a
12-year-old was hospitalized for depression and suicidal thoughts. In both
cases, the trial investigator determined the events were not related to
Singulair. In 2014, Stephane Bissonnette, a Merck manager at the time,
told the FDA panel that “suicidality was quite rare” in the trials.

The FDA also analyzed Merck’s data and generally agreed with its
conclusion, though the agency acknowledged the trials were short and not
designed to detect neuropsychiatric effects.

The FDA panel recommended rejecting the request to sell Singulair over-
the-counter because of safety concerns. The panel also called for new
studies on its neuropsychiatric side effects, a patient registry, and an
assessment of how well patients understood Singulair’s label.

The FDA tallied 82 suicides linked to Singulair and its generic versions
reported to its adverse-event database since 1998. Only 64 of the reports
provided an age; of those, 31 involved someone 19 or younger.

Reports of neuropsychiatric side effects “really should give us pause that
there may be something there we don’t understand,” Dr. Judith Kramer, Duke
medical professor and an advisory committee member, said at the 2014
meeting.

The FDA followed only half the recommendation: It declined to authorize
over-the-counter sales but also refused to order new studies, in part
because neuropsychiatric side effects were already a “known safety issue,”
an agency safety official said at the time.

The FDA told Reuters it declined to order more research because of
“feasibility concerns.”

In 2019, the FDA convened another advisory panel on whether the drug’s
side effects merited a black box warning. Before the meeting, the FDA
tallied 82 suicides linked to Singulair and its generic versions reported
to its adverse-event database since 1998. Only 64 of the reports provided
an age; of those, 31 involved someone 19 or younger.

https://www.reuters.com/investigates/special-report/assets/usa-lawsuits-
merck-singulair/fda-suicides.jpg?v=143601180823

Narratives included in reports to the FDA of suicides associated with
Merck’s asthma and allergy drug, Singulair, or generic versions. The
agency logged the incidents in its “adverse event” database, which tracks
potentially problematic drug side effects.
Still, agency staffers again said there was not enough evidence to merit a
black box warning, noting that the label already warned of potential
neuropsychiatric events.

FDA staff acknowledged the agency had the authority to require new
studies. But Merck now had little incentive to conduct expensive research
because its patent on Singulair had expired and its profits on the drug
had plummeted. Instead, Merck might just pull Singulair off the market, an
FDA official told the advisory committee in 2019.

Instead of requiring new studies, the FDA announced in March 2020 that it
would add a black box to the labels of Singulair and its generic
variations, warning of serious neuropsychiatric side effects including
suicidal thinking and behavior. The agency cited independent research from
2015 showing the drug’s distribution in the brain. The FDA advised
restricting use of the drug for treating allergies, saying it should not
be the first-choice treatment.

‘This does not make sense’

Reuters interviewed 16 patients or their parents who suspect that
Singulair caused psychiatric side effects. Many, like Nicholas England,
took a generic version.

England grew up in the rural town of Wise, Virginia. He was easygoing and
physically fit, and would refuse junk food when the rest of the family was
having it, said his father, Robert England. He believed his son may have
struggled to sleep after taking the drug, but otherwise seemed normal.

After Nicholas died, a police report noted that he didn’t have illicit
drugs in his system. The case puzzled sheriff’s investigators, Robert
said: “All these guys looked at me and said, ‘This does not make sense.’”

In the years when the FDA delayed action on Singulair, some parents began
contacting lawyers to explore taking legal action. Most, like the
Englands, were barred by court precedents from suing because their
children took a generic version of the drug. Kim Beck, an attorney who
eventually filed hundreds of lawsuits against Merck over Singulair, said
her firm turned away thousands more potential clients who had taken
generics.

The FDA’s 2020 regulatory action encouraged some patients to sue Merck.
Most of those lawsuits are in early stages, but Merck has had some success
with preemption defenses.

In Wisconsin, for instance, a mother sued Merck in 2020 claiming Singulair
caused her son to be institutionalized with severe depression. The boy was
prescribed Singulair in 2010, but switched to the generic version in 2012.

Merck argued the plaintiff couldn’t show the FDA would have approved a
stronger warning before 2012, when the boy was taking brand-name
Singulair. The drugmaker cited the agency’s 2011 rejection of the petition
by Gilpin and other parents to add such a warning.

A judge agreed, ruling that “the relevant federal and state laws in this
case irreconcilably conflict.” He dismissed nearly every claim in the
lawsuit, which the mother then dropped.

Merck accused of downplaying early evidence of drug’s brain impact

An early magazine advertisement for Merck’s breakthrough asthma and
allergy medicine, Singulair, featured a happy child, hanging upside-down
from a tree. Asthmatic kids could now breathe easier, the text assured,
and side effects were “usually mild” and “similar to a sugar pill.”

When the drug launched in 1998, its label said the drug’s distribution in
the brain was “minimal,” with no mention of psychiatric side effects.

Merck’s early safety claims later faced intense scrutiny amid reports over
two decades that patients, including many children, had died by suicide or
experienced neuropsychiatric problems after taking the drug. The FDA in
2020 ordered its most serious warning, known as a “black box,” on
Singulair’s label. And Merck now faces a raft of lawsuits alleging it knew
from its early research that the drug could impact the brain and that it
minimized the potential for psychiatric problems in statements to
regulators.

The lawsuits cite the research of Julia Marschallinger, a cell biologist
who has studied the drug along with colleagues at the Institute of
Molecular Regenerative Medicine in Austria. That team found in 2015 that
the drug’s distribution into the brain was more significant than its label
described. The FDA cited Marschallinger’s work when it ordered Singulair’s
black-box warning label.

In its original patent for Singulair, Merck cited other applications for
the drug, beyond asthma and allergies, including as a treatment for
“cerebral spasm,” a neurological condition. Lawsuits filed against Merck
cite this 1996 patent as evidence of Merck’s knowledge of the drug’s
potential brain impacts.

Merck declined to comment for this report.

In 2014, scientists in Austria reanalyzed Merck’s original animal studies
and noticed the drug decreased almost everywhere in the body 24 hours
after dosage – but not in the brain, where it increased.

When Merck first sought FDA approval for Singulair, an FDA analyst,
relying on company assertions, said in 1998 that “only a trace amount” of
the drug could be found in the brain, federal documents show. The FDA said
Merck’s data showed the presence of the Singulair “declined over time” in
all tissues.

Marschallinger and her colleagues in Austria came away with a different
finding when they reviewed Merck’s original research and did some of their
own. They started looking at Singulair as a potential dementia treatment
in 2011. They became interested in that prospect in part because of the
reports of psychiatric side effects, such as depression, agitation or
hallucinations, from patients and medical providers. While troubling, the
side effects showed the drug might affect the brain. The researchers
wanted to understand if it could benefit older patients with dementia.

In 2014, the scientists in Austria reanalyzed Merck’s original animal
studies and noticed the drug decreased almost everywhere in the body 24
hours after dosage – but not in the brain, where it increased over this
period, surpassing the amount in both the blood and the lungs. She
reported finding a “substantial amount” of the drug had reached the brain,
in contrast to Merck’s description of the brain distribution as “minimal.”

The FDA said Merck’s original animal studies were “quite limited and
cannot provide any definitive information about the montelukast levels and
activity in the brain.” The agency acknowledged that its reviewer’s
description that drug levels declined over time in all tissues “did not
fully reflect the data.”

As for Marschallinger’s finding that a “substantial amount” of the drug
had reached the brain, the FDA called it “a subjective characterization
that is not necessarily incompatible with the ‘minimal’ descriptor in
other contexts.” The researchers’ 2015 study, the FDA said, provided
additional evidence that the drug reached the brain but did not show any
specific harm.

Marschallinger said it would have been logical for the FDA to require
Merck to investigate the brain impacts more thoroughly once reports of
mental-health problems emerged.

“The FDA could have asked Merck to repeat the experiment or do it for an
even longer period of time,” Marschallinger said. “It’s not hard to do
this.”

Methodology

Reuters focused on federal appeals and Supreme Court decisions to measure
the success of the preemption defense in lawsuits that alleged corporate
negligence or defective products caused injuries or deaths. These cases
are important because they usually establish legal precedents that other
judges across the United States must follow.

Reporters worked with a specialist at Westlaw, a legal research service
owned by Thomson Reuters, to identify cases since 2001 that involved the
defense. They searched Westlaw’s database of federal court decisions for
opinions that contained the phrase “preempt” as well as additional key
words or phrases, such as “product liability,” “negligence,” “strict
liability,” and “failure to warn.” Reporters consulted with several
outside legal experts in developing the search terms.

The searches yielded nearly 800 opinions that a team of Reuters reporters
manually reviewed to determine if the preemption defense was at issue in
the opinion and if the case included allegations of physical harm to at
least one person. The review narrowed the potential universe to 257
relevant cases.

The reporters then read each opinion in those 257 decisions to determine
the outcome of the preemption defense. They marked cases “successful” when
judges granted all preemption claims. Cases were marked “partially
successful” when some claims were preempted but others were not. Cases
were marked “unsuccessful” when no claims were preempted.

Each opinion was reviewed separately by two reporters to ensure the
accuracy of the coding.


--
We live in a time where intelligent people are being silenced so that
stupid people won't be offended.

Durham Report: The FBI has an integrity problem. It has none.

No collusion - Special Counsel Robert Swan Mueller III, March 2019.
Officially made Nancy Pelosi a two-time impeachment loser.

Thank you for cleaning up the disaster of the 2008-2017 Obama / Biden
fiasco, President Trump.

Under Barack Obama's leadership, the United States of America became the
The World According To Garp. Obama sold out heterosexuals for Hollywood
queer liberal democrat donors.

President Trump boosted the economy, reduced illegal invasions, appointed
dozens of judges and three SCOTUS justices.