Counterpoint: All the Information Fit To Be Reported -- Fabricating American Symbolic Reality
***** KERNISKY **** EJC/REC Vol. 7, No. 1, 1997 ************
Counterpoint: All The Information Fit To Be Reported -
Fabricating American Symbolic Reality
Ivan F. Kernisky
Northern Michigan University
Abstract. This essay argues that journalism
should be separated from commercial interests and
redefined as an agent of public discourse and
public good. Given such redefinition, journalism
takes on a new social and ethical responsibilities
to society. The essay examines the role of news
sources such as whistleblowers within the context
of these new journalistic responsibilities.
When we define a situation we direct our
attitudes and communicative behavior . The
definition we place on a situation establishes the
basis for our action. (Thomas, cited in Wood,
1982, p. 56)
This paper will argue that news sources are a vital
element in public journalism. It will redefine the
journalistic function in society, and thereby separate it
from commercial and ideological motives. If journalism is
to serve the public in activating public discourse, then
investigative reporting and news sources bear a different
legitimacy and public responsibility towards the good of
Our understanding of journalism and the public sphere
is cast in a functionalist perspective with reporters
providing surveillance and interpretive roles thus shaping
and influencing public opinion. The media in this context
retain a power position in the role of agenda setters and
gatekeepers of American consciousness. Given that "...an
unprecedented degree of day-to-day control over the news is
high on today's corporate agenda" ("Tobacco's Chokehold,"
1995, p. 689; see also Parenti, 1993), mediated public
opinion may not necessarily represent, or reflect the public
good. If this current paradigm of journalistic media and
society was to be redefined, a new schema of relations and
responsibilities would materialize. Instead of journalists
defining their mission as selling information, a greater
benefit would be served if journalists redirected their
efforts and focus in activating the public to become
involved with public life through discourse.
Current analysis and criticism of news sources,
vis-a-vis, "whistleblowers" - a vital element in
investigative reporting, is documented from the perspective
of the corporate model of conducting business. In this
respect media as a corporate entity succumbs to the
"business think" of marketplace philosophy. In marketing
parlance, the news industry becomes an important component
in competitiveness, and thereby is defined and legitimized
like other commodities in the marketplace. When journalism
is operationalized and marketed in the same sphere as nuts
and bolts, its activities are managed and focused for the
good ofthe stockholders, not the public. Grossman (1996)
The nation has learned of the growing
vulnerability of mainstream news organizations,
which are becoming relatively minor subsidies of
huge global corporations with multiple financial
interests. Top corporate executives are paid to
concentrate on their companies' bottom line and
stockholders' returns rather than on their news
divisions' responsibilities to the public. That
vulnerability was exposed last summer  when
ABC caved in to a $10 billion libel suit by Philip
Morris. (p. 40)
In order to create a new legitimacy and rationale for
news sources, it is necessary to recontextualize journalism
by separating it from its commercial mission. When
journalism is redefined in terms of public discourse and
public good, it is stripped of its corporate culture and
ideology, and bears a new social and ethical accountability
to society. In this alter role of journalism, investigative
reporting inherits a crucial role of unearthing issues and
situations that are of public concern. In this respect,
when a source individual who at personal risk and peril
comes forward, he/she becomes an important asset in the
investigative journalistic field and public discourse
process. In this newly defined context, the derogatory
nature of a "whistleblower" is resignified as a news source.
Modern journalism in America has been anchored to
social responsibility theory, which rationalized an emphasis
on community, but at the same time provided for a
professional culture. Siebert, Peterson and Schramm in
_Four Theories of the Press_ describe six tasks that social
responsibility theory ascribes to the press:
(1) servicing the political system by providing
information, discussion, and debate on public
(2) enlightening the public so as to make it
capable of self-government,
(3) safeguarding the rights of the individual by
serving as a watchdog against government,
(4) servicing the economic system, primarily by
bringing together the buyers and sellers of
goods and services through the medium of
(5) providing entertainment,
(6) maintaining its own financial self-sufficiency
so as to be free from pressures of special
interests. (as cited in Bugeja, 1996, p. 45)
Hallin (1985) argues that the professionalization of
the news organization has diverted efforts from the public
sphere, and focused more attention on themselves - a common
effect of professionalism. Social responsibility theory
views the audience as "lethargic" thus justifying the
press's role in educating the public. The theory gives
priority to the press's importance in interpreting events,
thus stimulating the development of an informed citizenry.
The lethargy of the audience added to the activism of the
press means that corporate owners of the press have a great
deal of power in the molding of social opinion, which they
may not want to readily abdicate. The popularity and
addiction of journalistic interpretation of our culture is a
powerful tool in social orientation. Parenti (1988)
believes, "The social institutions of capitalist society
[become] the purveyors of its cultural myths, values, and
legitimating viewpoints" (p. 224).
Public journalism not only advocates including
gathering and interpreting functions as indicated in social
responsibility theory, but also adds the need to activate
the public (Allen, 1994). Public journalism advocates
shifting from reporting about a community to becoming an
active participant in the creation of community. It is an
attempt to harness journalism as an agency of change, rather
than a mirror of society. It is a philosophy and strategy
to empower citizens. Jay Rosen (1993), one of the founders
of public journalism, advocates that public deliberation is
possible and the press has a role in its creation.
"...[J]ournalist[s] must play an active role in supporting
civic involvement, improving discourse and debate, and
creating a climate in which the affairs of the community
earn their claim on the citizen's time and attention" (p.
3). Rosen views this public activation as an "expanded
sense of public responsibility. "While contemporary
journalism focuses its coverage on dominant personalities
and special interest groups, public journalism advocates
that public deliberation is a fundamental value to society
in arriving at general truths and collective self
governance. The ideas that support public journalism align
with two bodies of literature, deliberative democracy and
According to Habermas, the public sphere is defined as
an arena in which public concerns are debated by private
citizens (Calhoun, 1992). Membership in a society is
enhanced as well as a linkage created between state and
society through public discourse and public opinion. Holub
(1991) suggests that in order for the public sphere to
function, citizens require indiscriminate access and equal
opportunity to participate. The public sphere becomes the
site of deliberative matters of public concern for the
common good, and mass media become an important conduit and
trigger in this process. By providing an equitable
opportunity to enter into discussion and representing all
significant interests, media become a proactive agent in
fueling discourse. Curran (1991) advocates that a critical
role in this process is the partisan or investigative
information provided by the journalist.
The deliberative outcome of public discourse can only
be legitimate if free and reasoned agreement amongst equals
is present (Cohen, 1989, p. 22). Habermas further clarifies
deliberative outcomes in his guide for interpreters and
actors engaged in practical discourse:
(1) only those norms may claim to be valid that
could meet with the consent of all concerned,
in their role as participants in practical
(2) for a norm to be valid, the consequences and
side effects of its general observances for
the satisfaction of each person's particular
interests must be freely accepted by all, and
(3) an ethic is termed 'universalistic' when it
alleges that a moral principle, far from
reflecting the institutions of a particular
culture or epoch, is valid universally.
(Habermas, cited by Allen, 1995, p.15)
Through universal standards Habermas hopes society will be
able to achieve consensus. Benhabib (1990) argues that a
consensus can not necessarily be guaranteed, but rather a
consensus can be achieved through a fair process.
[w]hen we shift the burden of the moral test in
communicative ethics from consensus to the idea of
an ongoing moral conversation, we begin to ask not
what all would or could agree to as a result of
practical discourses to be morally permissible or
impermissible, but what would be allowed and
perhaps even necessary from the standpoint of
continuing and sustaining the practice ofthe moral
conversation among us. (p. 341)
When deliberative democracy and communicative ethics
are combined, they provide ethical parameters for the
American press in aiding in the creation of public
deliberation. The "watchdog" function of the press does not
fall by the wayside. The new mission for the press
encompasses surveillance and "public convener." A fine line
is developed between aiding discussion and dominating
discussion. The latter requires a strong ethical
commitment. Allen (1995) argues that "...one of the
fundamental problems facing society is not finding ways to
make democracy more efficient, but allowing disempowered
groups in a diverse society to play a formative role in the
creation of a just society" (p. 20). The parameters of an
alter form of journalism articulate a revised role for the
press to play in society - a role that enhances the
tradition of journalism, and at the same time stimulates
public deliberation for the common good.
The Right To Know
While print and broadcast journalists have no absolute
privileges similar to doctors, lawyers, and clergy, they
never-the-less are charged with and held accountable for the
surveillance and interpretation of our everyday world. The
functioning of our culture stems from the access and flow of
information in which the journalist plays out an essential
conduit. The quality of our being becomes directly related
to our level of awareness, and choice of participation in
this dynamic experiment of shared power. The premise of
self governance is predicated on representation, the
libertarian theorem of non-censorship, and public discourse.
An informed citizenry that chooses to participate in
the daily negotiation of oppositional political platforms is
dependent on the selection, emphasis, and breadth of events,
opinions, and criticism, of an ethical media. Thus the
responsibility of media as an integral player in the process
of constructing symbolic reality demands not only
professionalism, but a sense of moral responsibility. The
issue of the public's right to know and journalistic
priviledge are controversial issues. The public's right to
know is not among the rights listed in the Bill of Rights,
or explicitly recognized by the courts. If the public is to
make informed decisions and vote responsibly, the news media
by default become the channels of that awareness and access.
While journalists would like to believe that the
Constitution assigns them special privileges in serving the
public's right to know, the fact is contrary. Olen (1988)
argues that the public's right to know has to be recast into
the public's *need* to know and the journalists contract to
serve those needs. "In a democratic society such as ours,
certain kinds of information are indeed of critical
political importance. Whether there exists a right to know
or not, there is most definitely a need to know. And even
if public officials have the right to withhold comment on
such matters, we the public have a right to try to find out
the truth about them. Moreover, we rely on certain
journalists to hunt down and publicize that truth" (p. 11).
Olen goes on to say that journalists in their pursuit of
information and sources "...have a moral right to engage in
civil disobedience" as in cases related to divulging
Paramount to the moralistic stance of the journalist is
his/her access to information. Although mechanisms such as
wire services, press releases, reporters, and eyewitnesses
flood the journalists' desk with information of a newsworthy
status, other events of perhaps a greater urgency and
significance have difficulty in surfacing. Traditional
methods of accessing these buried events do not suffice,
thus the journalist has become dependent on "news sources"
in formulating stories and placing the respective
adversaries on notice. Both the journalist and news source
collaborate at great risks as there are severe sanctions in
the quasi-clandestine process. "The unnamed news source has
been called a safety valve for democracy and a refuge for
conscience, but also a crutch for lazy, careless reporters"
(Christians, Rotzoll & Fakler, 1987, p. 69).
The journalist and the news source exercise a symbiotic
relationship. Both actors play out an important role in the
needs of a safe social environment. Both actors are
embroiled in the forces of secrecy, freedom of speech, and
ethical responsibility. While there are opportunists
looking after their own agenda on both sides of this
equation, this aberrance should not mask the purpose of this
inquiry in adjudicating whose rights or needs should be
prioritized, and what price is to be paid or gained in the
long term. A11 too often in our culture the exception
becomes the event and our concern is blurred as to the norm.
The technique of confusing the issue and manipulating the
public agenda is a long standing propaganda technique.
Since there are no political absolutes to circumvent
organizational collusion, a conciliatory playing field might
best suit our temporary needs for a solution.
Anthony Smith (1995) in his book _Good-bye Gutenburg:
The Newspaper Revolution of the 1980's_ says that
"...investigation has become the most highly praised form of
journalism, taking the place of opinion leadership, the
historic purpose of the press (cited in Alexander and
Hanson, 1995, p. 116). Smith suggests that the
investigative reporter becomes the authority to whom the
public turns to for the whole truth. Ettema and Glasser
(1988) argue that "...news is a moralizing form of
discourse...that provides a forum for deliberating upon
moral action" (p. 25). The structure ofthis discourse is a
narrative form that asserts a moral authority. The value of
narrative structure facilitates the journalists' ability
"...to teach what it means to be moral beings and to judge
the moral significance of human projects" (p. 11 ). Ettema
and Glasser believe that investigative reporting maintains
and sometimes updates consensual interpretation of right and
wrong, innocence and guilt. They conceptualize the
journalist's task as the "evocation of righteous
indignation" (1988, p. 24).
Broadcast and print journalists often find themselves
as adversaries to organizations when investigating
activities of government, politics, business, and social
institutions. "Thousands of 'information specialists' and
public relations 'consultants' in both the government and
private sector devote careers to 'handling' the media and
steering coverage in certain directions (and not always
towards the news)" (Fink, 1988, p. 42). This time-honored
confrontation makes a critical contribution to society in
increasing organizational social responsibility. The
organization of investigative reporters and editors (IRE)
define their work as research into "...matters of importance
which some persons or organizations wish to keep secret"
(Defleur & Dennis, 1991, p. 398). The IRE advocates that
particular information in our collective midst is purposely
being concealed from public scrutiny and thus unorthodox
means need to be employed in order to publicize them. Bok
The alarms of whistleblowers would be unnecessary
were it not for the many threats to the public
interest shielded by practices of secrecy in such
domains as law, medicine, commerce, industry,
science, and government. Given these practices,
whistleblowers perform an indispensable public
service, but they do so at great human cost, and
without any assurance that they uncover most, or
even the worst abuse. (p. 228)
Investigative reporting dates back to the 1840's, and
through the years has uncovered corruption and scandal that
has lead to social debate and in many cases legislative
action. (See Table 1: Investigative Reporting - Notable
In the pursuit of a story, journalists often obtain
information by guaranteeing the identity of the source be
kept confidential. But confidentiality of sources can
hamper the credibility of a story. The key to ethical
journalistic behavior is delivering the story accurately and
effectively - "veiled attribution" can weaken that
reliability (Rivers & Mathews, 1988, p. 53). A journalist
should insist on attribution that would give the readers and
viewers the best credentials of the source. It is
imperative to communicate that the source is in a position
to substantiate the accuracy of the information being given.
Bok (1984) writes that "unless the information is
accompanied by indications of how the evidence can be
checked, the source's anonymity, however safe, diminishes
the value of the message" (p. 223).
News sources in many cases divulge information that
their respective organizations attempt to suppress, and
thereby risk disciplinary action - in many cases harassment
and/or separation. "Loyalty to colleagues and to clients
comes to be pitted against concerns for the public interest
and for those who may be injured unless someone speaks out"
(Bok, 1984, p. 214). A bonding and binding responsibility
is struck when both parties collaborate in divulging
information to the public. Not only must the source exhaust
all avenues within the organization in his/her concerns of
impropriety, but equally journalists must conduct verifying
measures and in concert with the editor make a responsible
decision whether to publish or broadcast.
The contract of confidentiality is an important link
between the journalist and future sources of information.
When a journalist stands fast by his/her commitment to
maintain in confidence the identity of the news source, then
the informant has a greater probability in surviving the
internal witch hunt, and other potential news sources may
more confidently speak out and take their chances.
Protecting the identity of the source is not only essential
for future contacts, but imperative in the process of the
public's right to information of a consequential nature.
Journalists claim that it is difficult if not
impossible to secure sensitive and controversial information
regarding crucial issues without relying on unnamed sources.
In many cases because of the critical nature of the
information, journalists discover themselves in dispute with
organizations in question - be it government secrecy,
private sector silence, or the pursuit of jurist prudence.
Organizations pressure the media to disclose the news
source's identity and then deal with that individual such
that others are dissuaded from following suit.
The courts also pressure the media to ensure that the
accused receive a fair trial. Judges and lawyers claim that
the Sixth Amendment takes precedence over the journalist's
plea of First Amendment rights. Journalists argue that if
they are forced to disclose their confidential sources,
future sources may be intimidated and disuaded from coming
forth. This latter action will translate into the public's
ignorance of questionable practices. The legal profession's
response is that journalists are only citizens with civic
responsibilities and should cooperate with the courts - they
[journalists] have no privilege (Overbeck, 1989, p. 348).
The confrontation between the media and the courts came
to a head during the 1960's when Earl Caldwell, a New York
reporter, refused a federal grand jury order to reveal
confidential information regarding an article about the
Black Panther Party. Caldwell believed that he had to honor
his promises of confidentiality as a matter of journalistic
ethics (Overbeck, 1989, p. 349). Although he was jailed for
contempt, a federal appellate court overturned the decision
ruling that Caldwell was protected by a "newsman's
privilege" inherent in the First Amendment's guarantee of
freedom of the press.
At the same time as the Caldwell case, two other
contempt disputes were in contention, Paul Pappas, a TV
reporter in New Bedford, Massachusetts, and Paul Branzburg
of the _Louisville Courrier Journal_. The U. S. Supreme
Court agreed to review all three cases. In a 1972 landmark
decision, "Branzburg vs. Hays," the Supreme Court in a
narrow 5-4 decision ruled that no First Amendment based
privileges applied to journalists (Hiebert, Ungurait & Bohn,
1991). Although Justice Lewis Powell voted with the
majority, he filed a separate opinion. "...while no
Constitutional privilege protected these particular
journalists" he wrote, "such a privilege would protect
journalists who were called to testify in some other
situations" (Overbeck, 1989, p. 350).
Critics have interpreted Powell's opinion to side with
the dissenting four justices thus concluding that five out
of nine believed that journalists had some constitutional
rights to protect confidential information under some
circumstances. While the Supreme Court ruling struck down
an absolute privilege, the dissenting justices along with
Justice Powell, believed that in certain situations First
Amendment rights did apply.
In assisting Grand Juries in ruling on the need for a
journalist's disclosure, the dissenting justices suggested a
* Is the information relevant to a probable
violation of the law?
* Can the information be obtained by alternative
* Are there any compelling and overriding
interests in the information? (Overbeck, 1989,
By the 1970's, 17 states had passed "Shield Laws" that
endorsed journalists' rights to protect a confidential
source. But contrary to state laws, the courts continue to
carve out exceptions to the Shield Laws, and invoke the
Supreme Court majority decision.
The Chilling Effect
Besides media's confrontation with the criminal courts,
there are other difficulties at the civil court level. In
civil matters each party has extensive rights to pretrial
"discovery." Persons who may be suing the media for libel,
for example, may during the discovery process ask for the
names of the journalist's sources. An individual suing the
media bears the burden of proof in proving the story was
published/broadcast with "actual malice." "Libel cases are
sometimes filed not because the plaintiff (the suing party)
expects to win the case, but merely as a ploy to identify
the source of the embarrassing party. In this way, a
corporation, for example, might be able to find (and fire) a
whistleblower within its ranks" (Overbeck, 1989, p. 352).
Media has little choice in the matter, for to refuse to
cooperate in the discovery process is to forfeit the
lawsuit. The _Los Angeles Daily Journal_ ordered its
reporters to comply with a judge's order to reveal sources
in a libel suit filed by Jerry Plotkin, a hostage in Iran.
Faced with losing the trial and a 60 million dollar
judgment, the reporters finally complied.
Attorneys have moved into the editorial decision-making
process and are encouraging self-censorship. Bruce Sanford,
former attorney for UPI and past president of the Society of
Professional Journalists says "[t]here's a lot of
self-censorship by editors unwilling to rock the boat. They
fear the heavy court costs that could come from a tough
investigation article" (Pickard, 1989, p. 355). The _Wall
Street Journal_ and ABC's _20/20_ have both settled out of
court to avoid the risk of a heavier award. In defending
itself against the Lt. Col. Anthony Herbert libel case,
CBS spent between three and four million dollars. And
another 1.5 million dollars was spent in the pretrial
preparation of the Westmorland libel suit. John V.R. Bull
of the _Philadelphia Enquirer_ sees a growing timidity
amongst journalists commonly referred to as the "chilling
effect." "Avoiding litigation by self-censorship adds a raw
economic factor to an industry that has claimed to be guided
by the interests of society and ethical principles"
(Pickard, 1989, p. 357-358). To add insult to injury, a
number of insurance companies that provide libel insurance
require confidential sources to be revealed during discovery
- refusal would result in the termination of the policy
(Overbeck, 1989, p. 352).
A number of questions arise from this quagmire. What
are the ethical obligations of the reporter to the source?
Divulging the source's identity can certainly spell disaster
for the individual and influence future sources. What if
the informant does not release the journalist from the
contract? To defy the courts can result in a jail sentence,
or forfeit a trial and require payment of the judgment. The
matter becomes more complex when examining the
responsibility of media management to the journalist. Can
the journalist be threatened with separation if he/she does
Another interesting obstacle to public discourse is the
journalists' misuse of alleged sources for fictionalizing
reality. The 1981 Janet Cooke's fabrication of a child drug
user caused the _Washington Post_ to retract the story and
return the Pulitzer Prize awarded the author. The aftermath
of the scandal caused a number of media outlets to adopt
policies that avoid stories founded by unidentified sources.
Following this type of administrative direction, news
stories of crime and corruption in inaccessible places would
never be reported. What becomes the ethical dimension of
news policies that circumvent the public's awareness?
A more recent debacle which tarnished the profession
was NBC's _Dateline_ segment of the fire risks in some GM
trucks. The main ethical lapse was NBC's "...use of hidden
and unmentioned toy rocket engines to make sure fire was
ignited in the crash" (Denniston, 1993, p 46). The doctored
demonstration was aired during a "sweeps" period and was
seen in eleven million television households. GM had been
fighting scores of lawsuits in regards to the safety of its
trucks, NBC's blunder helped repair some of GM's
unflattering image. Michelle Gillen, a staff correspondent,
after repeated objections to the stunt, sounded the alarm.
Michael Gartner, President of NBC News who "...initially
defended what is indefensible in journalism... " (Cleghorn,
1993, p. 41), lost his job. Cleghorn, writing in _American
Journalism Review_ summarized the fraudulent journalism,
"...no code, no declaration of future intent, can substitute
for individual integrity" (1993, p. 4).
Suzanne Garment (1991), a resident scholar at the
American Enterprise Institute for Public Policy Research
believes that the post-Watergate years of news media's
influence in society is diminishing. She views journalists
as having abused their "right to know" as a "universal
search warrant." Juries seem to be awarding greater
judgments to individual plaintiffs accusing the news outlets
of wrong doing. "...[G]overnment and private bureaucracies
from the military to big corporations, are likely to try to
take advantage of this shift in attitude to cut back on
journalist's access to information" (p. 44). If this trend
of using the First Amendment as a smokescreen continues,
argues Garment, the press may in the end be the losers when
legislatures consider the privacy issue. Jane E. Kirtley
writing in the _National Law Journal_ regarding CBS's
decision to suppress its interview regarding allegations of
nicotine manipulation in cigarettes said, "It is a sad day
for the First Amendment when journalists back off from a
truthful story that the public needs to be told because of
fears that they might be sued over the way they got the
information" (Grossman, 1996, p. 47).
The complexity of our multicultured setting can not be
reduced and interpreted in simplistic sound-bites. The
diversified nature of our make-up necessitates a forum for
the exchange of mind sets in the task of negotiating a moral
direction and consensus. Our republic is historically
predicated on responsible collective interaction. Public
journalism and technology offer some solutions towards
hearing each other, and participating in the democratic
experiment. While public journalism is called upon to alert
us and activate discourse, technology offers new channels of
access to diversified sources and on-line interaction. Our
stratified society demands the possibility of
multi-directional dialgoue. The fabrication of American
symbolic reality must be influenced by multiple
perspectives. In this context, the legitimacy of the
messenger must be re-emphasized and the public spere
re-prioritized. Encouragement, not suppression, should be
the hallmark of a public sphere that accomodates the
In Lord Northcliff's (1865-1922) words:
The power of the press is very great, but not so
great as the power of suppress.
Table 1: Investigative Reporting - Notable Scandals
1840 - James Gordon Bennett, (_New York HeraId_),
investigating the murders of prostitutes in New
1890's - Elizabeth Cochrane's investigation of
human conditions at Blackwell's Island, an
1920's - the Teapot Dome scandal: Secretary of the
Interior Albert B. Fall leasing drilling rights
of federal oil reserves to private developers.
1970 - Watergate: Bernstein and Woodward
(_Washington Post_) exposing a conspiracy by the
White House, CIA, and others to cover-up covert
1971 - Pentagon Papers, a forrner defense
department analyst leaked a massive official
analysis of U.S. involvement in the Vietnam War.
1972 - three engineers alert the public to defects
in the breaking mechanisms of the Bay Area Rapid
Transit System (BART).
1970's - employee testifies that a chemical
company mistakenly shipped PBB's to state
1980 - _Atlanta Journal and Constitution_ printed
a multi-part series on how area banks were
discriminating against black home-buyers who
were seeking mortgage loans.
1980's - ABSCAM, anonymous revelations from within
the Dept. of Justice concerning congressional
investigation of classified military secrets.
1990 - disclosure of plans by European and
American companies to increase the proliferation
of chemical weapons-producing technology in the
1995-6 - CBS's allegation that Brown and
Williamson Tobacco Corp. squelched research on
safer cigarettes, altered documentation, used
additives known to cause cancer, and lied to
Congress about addictive qualities of tobacco.
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Bohm, 1991, Dominick, 1990; Fink, 1988, Grossman,
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