By Sheri H. Mecklenburg, Assistant U.S. Attorney for the Northern District of Illinois, Chicago, Illinois

The recent attempted bombings in London and Glasgow, like the earlier suicide bombings of the Madrid and London transit systems, leave no doubt that the threat of terrorism now comes from local cells, thrusting local police into a role once thought of as the purview of international and federal agencies: that of antiterrorism combatants. As a result of these incidents, police chiefs in major U.S. cities must now equip their officers to confront not only gangs, guns, and drugs but also suicide bombers like those seen in London, Glasgow, and Madrid. As local law enforcement agencies refine their strategies to combat urban crime, potential suicide bombers represent a challenge that traditional local law enforcement policies, practices, and training are particularly inadequate to address. Although some elite units in big-city departments have trained for the possibility of suicide bombers, the average U.S. cop on the street is ill prepared to face a suicide bomber, and the traditional training given to most officers provides them with tools that may actually increase suicide bombers’ chance of success.¹

Suicide Bombers in the United States

The terrorist attacks of September 11, 2001, were not the first suicide bombings in the United States—and likely will not be the last.² As early as July 1997, the New York Police Department (NYPD) foiled a double–suicide bombing plot against the New York City subway system just hours before the planned bombing. The offenders were linked to al Qaeda.³

Just two years later, law enforcement foiled yet another planned suicide bombing in the United States, also linked to al Qaeda. On December 14, 1999, Ahmed Ressam attempted to cross the border from Canada into Port Angeles, Washington. The customs inspector noticed that he was evasive and appeared suspicious. She referred him to a secondary checkpoint, where agents searched his car. The agents discovered in the trunk four boxes of homemade timing devices and 12 bags of powder, which later was identified as containing 124 pounds of urea and sulfate, ingredients for making bombs. Although Ressam attempted to bolt upon discovery of the powder, the agents gave chase and apprehended him after pursuing him for several blocks. Interrogation disclosed that Ressam intended to make a 200-pound bomb, which he planned to detonate in the crowded terminal of the Los Angeles airport at the height of the millennium celebration. Ressam, since labeled the “Millennium Bomber,” was convicted in March 2001 and, facing 130 years in jail, began cooperating with the government. His cooperation disclosed ties to al Qaeda and resulted in his identification of and testimony against several al Qaeda operatives.⁴

Locally Organized Terrorism: A New Strategy?

On March 11, 2004, Madrid suffered a series of coordinated bombings on its commuter trains, killing nearly 200 people and injuring almost 2,000 more. On July 7, 2005, London suffered four bomb attacks on three trains and a bus, leaving more than 50 people dead and 700 injured. On September 1, 2005, one of the London bombers appeared on a video declaring his ties to al Qaeda. On September 11, 2005, al Qaeda released a video announcing a campaign of suicide bombings throughout the world. And just this year, physicians who are living and working in England and Scotland were arrested for attempted car bombings in London and Glasgow.

In fact, an al Qaeda campaign of suicide bombings in the West might have been hatched months before the Madrid train bombings. In December 2003, a Norwegian intelligence officer came across a document on the Internet that he initially disregarded as simply another al Qaeda strategy for getting the United States out of Iraq. After the Madrid train bombings, however, the Norwegian officer returned to the document, realizing that it reflected a strategy for isolating the United States in Iraq, by forcing out allies through a series of suicide bombings in the allied countries.⁵ The Internet document analyzes the likely ineffectiveness of suicide bombings in Poland, characterizing the population as supportive of the war and able to withstand high casualty rates. After dismissing Poland as a likely target, the document presents a sophisticated analysis of Spain’s internal politics. The document characterized the Spanish population as unsupportive of the war and unable to tolerate casualties, concluding that the Spanish population could handle “two, maximum three blows.” In fact, the timing of the Madrid train bombings just before a national election appears to have influenced the election of the Socialist Party candidates, who advocated the withdrawal of the Spanish troops from Iraq and began that withdrawal shortly after taking office. The Internet document also analyzes the effectiveness that suicide bombings in London would have on withdrawal of British troops from Iraq.

Some have asked why al Qaeda would post its strategy on the Internet. Perhaps in response to the tremendous foreign intelligence efforts aimed at stopping terrorism following September 11, 2001, al Qaeda no longer can count on painstaking planning and prolonged training of terrorists at its camps. Perhaps the organization is now counting on its Internet missives to encourage local cells, such as the London bombers, to carry out its missions. Los Angeles chief of police William Bratton has aptly noted the effect of local terrorist cells on local law enforcement agencies in reflecting on the 2005 London bombings:

[T]errorist cells seem cut off from Al Qaeda’s headquarters. Now, rather than the well-financed groups of highly trained “professional” terrorists right out of Bin Laden’s camps, we are dealing with a new breed of young, educated men who are living among us in the United States and Europe. They are following Al Qaeda-influenced websites or heeding the calls to action by radical Imams. Without financing or logistical support from Al Qaeda, their attack plan may be whatever plan they can cobble together with imagination and Internet research. Because of that, now more than ever, it is more likely that the terrorist plot is going to be uncovered by the cop on the beat than a foreign intelligence source.⁶

Indeed, breeding of local terrorists means that local law enforcement agencies will play a greater role in both detecting and preventing terrorism. Because suicide bombers live among ordinary people, these people are the most likely to become aware of suspicious activity and to report such activity to their local police department. Local police must be trained to recognize the value of immediate investigation of citizen tips about such suspicious behavior, even if the reported conduct does not reflect traditional indicia of criminal conduct.⁷

Local Law Enforcement Tools for Combating Terrorism

Once local law enforcement agencies receive a threat of a suicide bombing, they must be ready on very short notice to deploy their resources and adapt their common tools to thwart terrorists. Such simple tools as increased traffic enforcement can lead to the apprehension of potential offenders.⁸ Dogs trained to detect bombs can also be used at traffic stops, provided that they are used within the confines set forth by the U.S. Supreme Court in Illinois v. Caballes.⁹ In Caballes, the Court held that drug- or bomb-detecting canines can be used during a traffic stop if the initial stop is lawful, if the use of the canines does not prolong the stop, and if the dogs are trained to detect only contraband and not to “hit” on legitimate property. This means that local law enforcement agencies must have canine units on the scene in advance rather than detaining a driver to bring in bomb-sniffing dogs.

Roadblocks represent another tool against suicide bombers. The Supreme Court made it clear, in City of Indianapolis v. Edmond, that stopping a car at a roadblock constitutes a seizure within the meaning of the Fourth Amendment.¹⁰ The Court noted that the use of roadblocks to stop cars without individualized suspicion is permissible in limited circumstances, such as sobriety checkpoints, checks for drivers’ licenses and registration, and border patrol checkpoints.¹¹ Although the Edmond Court refused to extend the use of roadblocks to detect illegal drugs or other ordinary criminal wrongdoing, it agreed that the “Fourth Amendment would almost certainly permit an appropriately tailored roadblock set up to thwart an imminent terrorist attack. . . . ”¹² Thus, if local law enforcement agencies have specific information of a potential suicide bombing, a roadblock tailored to that information should be permissible.

It appears that only specific threats against a public event will justify searches of those attending public gatherings where First Amendment rights are implicated.¹³ General terrorism concerns or elevated terrorism levels likely will not justify either searches of the personal belongings of those attending a public gathering, or use of metal detectors at a public gathering, absent a specific terror threat.¹⁴ In response to an argument raising general terrorism concerns to justify searches of individuals attending a public gathering, one court noted that no evidence of a specific threat was introduced, further stating, “While the threat of terrorism is omnipresent, we cannot use it as the basis for restricting the scope of the Fourth Amendment’s protections in any large gathering of people. In the absence of some reason to believe that international terrorists would target or infiltrate this protest, there is no basis for using September 11 as an excuse for searching protestors.”¹⁵

That same court also rejected the notion that the Department of Homeland Security’s elevated threat advisory level justified the searches. Observing that the threat level has been elevated for the majority of its time in existence, the court stated, “Given that we have been on ‘yellow alert’ for over two and a half years now, we cannot consider this a particularly exceptional condition that warrants curtailment of constitutional rights. We cannot simply suspend or restrict civil liberties until the War on Terror is over, because the War on Terror is unlikely ever to be truly over.”¹⁶ Thus, only a specific threat will justify the targeted use of law enforcement tools to prevent a suicide bombing.

Local Law Enforcement Deadly-Force Policy and Practices

Despite the best intelligence, detection, and prevention, there is likely to be a time when rank-and-file local law enforcement officers confront a suicide bomber on the street. With no time to call in the bomb squad or special weapons and tactics (SWAT) team, cops on the street will have to act quickly, according to their training on deadly force. The traditional notions of deadly force, however, do not apply to suicide bombers.¹⁷

The Supreme Court established the constitutional limits on the use of deadly force by law enforcement officials in Tennessee v. Garner.¹⁸ In that case, the Court held that the use of deadly force is a seizure subject to the reasonableness standards of the Fourth Amendment. The Court allowed that where an officer has probable cause to believe that a suspect poses a threat of serious physical harm, either to the officer or to others, it is not constitutionally unreasonable to prevent escape by using deadly force. The Court further explained that “if the suspect threatens the officer with a weapon or there is probable cause to believe that he has committed a crime involving the infliction or threatened infliction of serious physical harm, deadly force may be used if necessary to prevent escape, and if, where feasible, some warning has been given.”¹⁹

Local law enforcement agencies usually apply the principles of Garner to the situation of a “man with a gun,” by training their officers to shoot only if the gun is pointed at an officer and, even then, to give a warning to drop the gun. Many departments have adopted a policy stricter than that allowed by the Supreme Court, prohibiting shooting at offenders, fleeing or otherwise, unless there is an “imminent” danger to the officer or others. Imminent is often defined as whether the offender is, in fact, making an irreversible move to shoot. Lawsuits arising out of police shootings often focus on whether the police officer identified himself and gave a warning before shooting and whether the offender was imminently ready to shoot or was retreating. Experts are brought in to debate whether bullet wounds in the back are indicative of whether the offender was running away or whether the police began shooting while the offender remained an imminent threat.

In the context of suicide bombers, however, this debate is irrelevant. Suicide bombers always pose an imminent threat of death and serious injury, whether they are moving toward or fleeing from their target, for at any time they may detonate. Suicide bombers with their back toward, or backing away from, officers and the public are just as dangerous as those facing or moving toward officers and the public. Even suicide bombers some distance away remain an imminent threat: if an officer is within shooting distance of a bomber, then the bomber is certainly within range of killing the officer. In assessing the use of deadly force against a suicide bomber, officers must be trained to redefine imminent danger, for it is very different from the “man with a gun” situation.²⁰

In addition, the Supreme Court noted that a warning should be given “if feasible,” and officers are regularly trained to give such warnings. However, a warning is most likely not feasible when confronting a suicide bomber. The purpose of a warning is to allow the “man with the gun” to drop the gun and surrender peacefully without being shot. If law enforcement officers confronting suicide bombers issue a warning to stop, bombers, knowing that they have been detected and presumably ready to die, likely will simply detonate. The warning itself may encourage bombers to act sooner, giving officers even less time to assess their options and the public even less time to seek safety. Nevertheless, local law enforcement practice encourages warnings before the use of lethal force as part of its continuum-offorce training, a practice that can prove dangerous when applied to suicide bombers.

Other traditional policies and practices also may put officers in greater danger when confronting suicide bombers or bombs detonated by remote devices. For instance, officers confronting a dangerous situation often immediately use their radio to inform their agency of the threat and ask for assistance. Officers may not be trained to know that their radio frequency could set off a bomb and that instead, they should immediately turn off their radio. Similarly, use of a cellular phone can detonate a bomb. Officers trained to use alternative means of force, such as a Taser device, also may not know that the electrical charge of the Taser can detonate a bomb. If suspects appear to surrender, traditional training encourages officers to approach the offenders and pat them down for weapons. In the context of suicide bombers, the officers’ approach and pat-down may be the very things that increase their danger and set off the bomb.

If deadly force is used, officers are traditionally trained to shoot at the center of an offender’s body mass in order to increase the likelihood of a hit. However, a shot to the center of a suicide bomber’s body mass may be the very act that detonates the bomb carried on the bomber’s body. A shot to the center of a suicide bomber’s body mass also may, rather than immediately incapacitate the bomber, allow the bomber a few extra seconds to detonate before succumbing to the bullet. Therefore, experts recommend that when officers confront a suicide bomber, lethal force should take the form of a shot to the head rather than to the center of body mass.²¹

The use of deadly force, without warning, on a suspected suicide bomber who appears to be fleeing, followed by a shot to the head, causes ethical concerns for U.S. police officers and the public alike.²² The difficulty of such a policy has led one expert to opine that most U.S. police departments will not adopt an effective suicide bomber policy until after a suicide bombing occurs on U.S. soil.²³

The difficulty of reconciling traditional police policies with those considered effective to stop suicide bombers is apparent in the few attempts made so far to draft a written law enforcement policy on confronting suicide bombers. The U.S. Capitol Police adopted the first written policy for local law enforcement officers in the United States confronting suicide bombers on the street.²⁴ This progressive policy recognizes the need to maintain distance rather than approach the suspect, the danger of secondary devices, the danger of using the radio when confronting a suspected bomber, and the necessity of shooting at the suspect’s head when using lethal force. Nevertheless, the policy demonstrates the tension between traditional policing perspectives and confronting suicide bombers beginning with the preamble: “The preservation of life and the protection of property will be the foremost consideration of the Department in the event of a suicide bomb threat. . . . This includes the life of the suspected bomber.” The policy directs that the first officer on the scene “[o]rder the suspect to stop all movement.” The policy directs that if suspects comply with an officer’s order to stop, officers should then order suspects to open their clothing to reveal their torso and then to lay prone on the ground. Of course, the warning itself may give bombers notice to set off their bomb, but even if they hesitate, they will have additional opportunities to detonate when touching their clothing and when lying down. Even the friction of moving to the ground can unintentionally detonate the bomb. Although warnings feasible in traditional law enforcement confrontations may still be feasible when officers confront suicide bombers, it is extremely unlikely to be the case, and officers need to be trained properly to make this critical judgment.

In July 2005, the IACP issued training keys on suicide bombers that also demonstrate the conflict between traditional policing and confronting terrorism.²⁵ The IACP training keys recognize the particularities of dealing with suicide bombers and aptly note the necessity of maintaining a safe distance and the danger of using radios, Tasers, and other electrical discharge devices. The IACP explains that officers need not wait to use lethal force until the threat of death or serious injury is imminent. However, the issue is not whether officers must wait to use lethal force until the threat of death or serious injury is imminent; the issue is recognizing that the threat of death or serious injury is always imminent when facing an individual outfitted with a bomb. The IACP also recommends that before using lethal force against a suicide bomber, officers should, “[i]n open areas, fir[e] a warning shot in the air to get members of the public in covered or prone positions.” Not only does this practice ignore the dangers of giving suicide bombers notice that they have been detected, but firing a warning shot in an area where there are members of the public is dangerous in itself. The IACP training keys drew considerable attention for advocating that “if lethal force is justified or authorized, aim for the head.” The media, and hence the public, misunderstood this recommendation as a novel “shoot-to-kill” policy, when in fact all use of lethal force, including a shot aimed toward the center of body mass, is by definition a shoot-to-kill decision.²⁶

The London subway bombing incident illustrates the public’s misunderstanding of what is defined as a “shoot-to-kill” policy. On July 21, 2005—just 14 days after four bombs killed more than 50 and injured more than 700—London police discovered four additional bombs on the subway and a bus, all of which malfunctioned, resulting in no injuries. With tension high, the next day the police encountered Jean Charles de Menezes on the subway, who reportedly was wearing inappropriately bulky clothing, ran from the police, and ignored orders to halt. Believing that they had encountered another suicide bomber, the officers on the scene, in radio contact with supervisors, acted on orders to shoot and put seven shots into Menezes, all in the head. It turned out that Menezes was not a suicide bomber but a 27-year-old Brazilian immigrant who had moved to London to work. In the wake of the discovery that Menezes was not a suicide bomber, there has been considerable debate about the “shoot-to-kill” policy,²⁷ and it has been reported that the policy initially had been kept secret due to the concern over public acceptance.²⁸ As with the attention directed at the IACP training keys mentioned earlier, the debate has not recognized the fact that the decision to use lethal force of any kind is a “shoot-to-kill” choice. Despite the public concern, London police announced that the deadly-force policy of shooting potential suicide bombers in the head would remain.²⁹

In the United States, a similar incident prompted surprisingly little debate. On June 29, 2005, a man walked into the federal courthouse in Seattle, Washington, and claimed that he was going to blow up the building. He carried what appeared to be a grenade and had a backpack strapped to his body. After evacuating the building, Seattle police shot the man in the head. The man lay where he fell for two hours, without medical attention, until the police could determine the danger from the grenade or if there was a bomb in the backpack. The World War II–era grenade turned out to be inactive, and the portable x-ray machine using digital film purchased for detecting bombs revealed that the backpack contained a cutting board. Perhaps the express verbal threats made by the man in Seattle, as opposed to officers’ own assessment of the threat in the London shooting, contributed to public acceptance of the response of the Seattle police.³⁰

As of this writing, the National Bomb Squad Commanders Advisory Board is in the process of developing guidelines for responding to bombers, including suicide bombers. The guidelines are expected to address 14 situations, sorted into five categories, and to recommend that when confronting suicide bombers, officers should not shoot near the bomb, that is, not at the center of body mass. Presumably, the guidelines will suggest shooting at the head. Although bomb squad officers are invaluable in dealing with bombs detonated by remote devices, a suicide bombing incident may well be over before bomb squad officers can reach the scene; therefore, law enforcement agencies must train their street officers about the specifics of confronting suicide bombers, which is very different from the standard continuum-of-force training provided to most rank-and-file officers.

Conclusion

In conclusion, local law enforcement agencies will have to adapt their traditional policies and training to address new dangers when confronting suicide bombers. Changes cannot take place simply on paper, nor can they be limited to specialized units, because beat officers are the most likely to find themselves facing suicide bombers on the street. Those officers, as in all situations, must be able to count on their training, not their luck.³¹■

Author’s note: This article is based on a speech given by the author at the annual IACP conference in Miami, Florida, September 2005. The views expressed herein are solely those of the author and are not necessarily those of the U.S. Department of Justice.

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Notes:
¹Some municipal police departments, such as those of Chicago, Seattle, Los Angeles, Miami, and Boston, have engaged in antiterrorism training, including training specifically aimed at suicide bombers. Since the terrorist attacks of September 11, 2001, the New York Police Department is regarded as a major antiterrorism agency. See William Finnegan, “The Terrorism Beat,” The New Yorker, July 25, 2005, 58.
²Robert Mueller, Director of the U.S. Federal Bureau of Investigation, recognized in a May 20, 2002, speech at the National District Attorneys Association’s spring Capital Conference, Alexandria, Virginia, “I think that we will see [suicide bombings] in the future. I think it is inevitable.” The motivations that are increasingly likely to bring suicide bombers to U.S. soil are beyond the scope of this article, but many useful reference materials discuss the profiles, motivations, and history of suicide bombers. See, e.g., Robert Pape, Dying to Win: The Strategic Logic of Suicide Terrorism (New York: Random House, 2005); and Mia Bloom, Dying to Kill: The Allure of Suicide Terror (New York: Columbia University Press, 2005).
³See Samuel Katz, Jihad in Brooklyn: The NYPD Raid That Stopped America’s First Suicide Bombers (New York: New York American Library, 2005).
⁴See “Millennium Bomber Sentenced to 22 Years: Ahmed Ressam Apprehended by Customs Officers in Port Angeles in 1999,” U.S. Customs and Border Protection Web site, http://www.cbp.gov/xp/cgov/newsroom/news_releases/archives/2005_press_releases/072005/07272005.xml (accessed August 1, 2007). See also “Inside Ressam’s Millennium Plot,” PBS Web site, http://www.pbs.org/wgbh/pages/frontline/shows/trail/inside/ (accessed August 3, 2007).
⁵See, e.g., Jay Tolson, “Cracking Al Qaeda’s Code,” U.S. News & World Report, May 9, 2004, http://www.usnews.com/usnews/culture/articles/040517/17strategy.htm (accessed July 13, 2007). The original document, written in Arabic, is available through http://www.mil.no/felles/ffi/start/article.jhtml?articleID=71589 (accessed July 13, 2007).
⁶Bratton, “Responding to Terror,” Subject to Debate (newsletter of the Police Executive Research Forum) 19, no. 7 (July 2005): 2.
⁷The most recent attempted car bombing in London was foiled when ambulance drivers, attending to a routine call of a sick person in a crowded nightclub, reported smoke coming from a car parked nearby. Investigation showed that the car was packed with explosives, rigged with nails, and set for detonation through a mobile phone. See “Police Avert Car Bomb ‘Carnage,’” BBC News Web site, http://news.bbc.co.uk/1/hi/uk_news/6252276.stm (accessed August 1, 2007).
⁸Oklahoma City bomber Timothy McVeigh was apprehended as a result of an ordinary traffic stop. See Whren v. United States, 517 U.S. 806 (1996), which permits traffic stops even if the goal is to deter crime other than traffic infractions.
⁹543 U.S. 405 (2005).
¹⁰531 U.S. 32 (2000).
¹¹Id. at 38–39.
¹²Id. at 44. See also Norwood v. Bain, 143 F. 3d 843 (4th Cir. 1998) (noting that the reasonableness of a checkpoint seizure takes into consideration the gravity of the interest sought to be advanced and the degree to which the seizures advance that interest); and U.S. v. Pulido-Baquerizo, 800 F. 2d 899 (9th Cir. 1986) (in upholding the search of an airline passenger’s briefcase at an airport, the court noted that the government interest in preventing terrorism at airports is significant enough to allow the intrusion, in light of bombings and hijackings at airports).
¹³At a ticketed event, the ticket itself can establish consent to search, but a public gathering implicating First Amendment rights, such as a demonstration, must be open to everyone.
¹⁴Bourgeois v. Peters, 387 F. 3d 1303 (11th Cir. 2004); Stauber v. City of New York, 2004 WL 1593870 at 31–32 (S.D. N.Y. 2004).
¹⁵Bourgeois, 387 F. 3d at 1311.
¹⁶Id. at 1312.
¹⁷As Bruce Hoffman, a terrorism expert at the Rand Corporation, warned, “[t]he police standard operating procedure of addressing a suspect and telling them to drop their weapon and put their hands up or freeze is not going to work with a suicide bomber. . . . You’re signing your own death warrant if you do that.” Quoted in Sari Horwitz, “Police Chiefs Group Bolsters Policy on Suicide Bombers,” Washington Post, August 4, 2005.
¹⁸471 U.S. 1 (1985).
¹⁹Id. at 11–12.
²⁰Of course, officers also must be trained to make what may be a very difficult assessment of whether a person is actually a suicide bomber, a potentially complex determination beyond the scope of this article. This article addresses the use of force once the assessment has been made that the person is, in fact, a suicide bomber.
²¹See International Association of Chiefs of Police, Suicide (Homicide) Bombers, parts 1 and 2, Training Keys 581 and 582 (Alexandria, Va.: International Association of Chiefs of Police, 2005), http://www.theiacp.org/pubinfo/IACP581SuicideBombersPart1.pdf and http://www.theiacp.org/pubinfo/IACP582SuicideBombersPart2.pdf (both accessed July 16, 2007); see also training materials for “Prevention & Response to Suicide Bomb Incidents,” and “Incident Response to Terrorist Bombings” (May 2005), which are available from the New Mexico Institute on Mining and Technology, Energetic Materials Research and Testing Center (www.emrtc.nmt.edu), 801 Leroy Place, Socorro, NM 87801.
²²Acceptance likely will depend upon whether the officer’s assessment was correct, a judgment that can be made only in hindsight. There are no guarantees of certainty of a suspect’s intentions and capabilities, and many of the signs attributable to suicide bombers can also be innocent characteristics. The issue, beyond the scope of this article, is how much intelligence an officer needs to determine that the suspect is in fact a suicide bomber.
²³The expert identified is David Heyman of the Center for Strategic and International Studies. See Horwitz, “Police Chiefs Group Bolsters Policy on Suicide Bombers.”
²⁴United States Capitol Police Operational Directive, “Responding to a Suicide Bomber,” effective February 3, 2004.
²⁵International Association of Chiefs of Police, Suicide (Homicide) Bombers, parts 1 and 2.
²⁶See, e.g., Horwitz, “Police Chiefs Group Bolsters Policy on Suicide Bombers,” claiming that officers using lethal force are usually taught to “shoot to stop” or “shoot to neutralize” rather than to shoot to kill. In fact, the definition of lethal force is “shoot to kill,” and no local law enforcement officers are trained to use firearms in any situation that does not justify lethal force.
²⁷See Vikram Dodd, “Police Rethink Shoot to Kill Policy,” The Guardian, August 20, 2005.
²⁸See Sophie Goodchild, “Police Chiefs Urged Secrecy Over Shoot-to-Kill Anti-Terror Tactics,” The Independent, February 12, 2006.
²⁹Still, it is notable that an assistant commissioner of the London Police, commenting on the policy to shoot suicide bomber suspects in the head, reportedly claimed that the department’s policy was “shoot to incapacitate” rather than “shoot to kill.” “We will not accept ‘shoot to kill’ as a characterization of what we do.” Quoted in “London Police Defend Using Force against Suspected Suicide Bombers,” USA Today, October 27, 2005.
³⁰See, e.g., “Man Killed at Seattle Courthouse,” CBSnews.com, June 20, 2005, http://www.cbsnews.com/stories/2005/06/21/national/main703356.shtml (accessed July 18, 2007).
³¹As the Irish Republican Army once put it in a statement directed at former British prime minister Margaret Thatcher, “[W]e only have to be lucky once; you will have to be lucky always.”

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