58 DePaul L. Rev. 919 (2008-2009)
State Constitutions and Legislative Continuity in a 9/11 World: Surviving an Enemy Attack

handle is hein.journals/deplr58 and id is 927 raw text is: STATE CONSTITUTIONS AND LEGISLATIVE
CONTINUITY IN A 9/11 WORLD: SURVIVING
AN ENEMY ATTACK
Eric R. Daleo*
INTRODUCTION
Six minutes after the California State Assembly approved a mea-
sure to solve the State's energy crisis, an 80,000 pound, eighteen-wheel
tractor-trailer intentionally crashed into the south entrance of the
state capitol at a speed of fifty miles per hour.1 The impact caused a
massive explosion with flames on the ground floor reaching as high as
third-floor windows, charring inside hallways and destroying a legisla-
tive committee hearing room.2 The truck's driver was killed instantly
in a ball of fire.'3 Inside the legislative chamber, police instructed
Assembly members to evacuate, and the Assembly's loudspeaker sys-
tem warned, This is not a drill.'4 Hundreds of legislators and staff
fled the state capitol in the moments following the explosion.5
The January 16, 2001 attack on the California State House was not
perpetrated by a foreign terrorist group, but rather by Mike Bowers-
a parolee despondent over the breakup of his marriage.6 His cargo
was not an explosive device, but rather cans of sweetened condensed
* J.D., Rutgers University School of Law-Camden; M.A. in History and Public Policy, The
George Washington University; B.A., The George Washington University. Rutgers Distin-
guished Professor Robert F. Williams provided extraordinarily helpful feedback and was singu-
larly instrumental in my decision to publish this piece. Professor Williams has devoted much of
his livelihood to imprinting on his students the importance and relevance of state constitutions in
our federal system. Although I hope this Article is a positive reflection on his teaching and the
significant impact he has had on my legal studies, all errors are my own.
1. Julie Tamaki & Carl Ingram, Truck Driver in Capitol Crash Had History of Mental Illness,
Violence, L.A. TIMES, Jan. 18, 2001, at A3, available at 2001 WLNR 10547559; Mareva Brown et
al., Truck Rams Capitol: Driver Killed in Fiery Attack, SACRAMENTO BEE, Jan. 17, 2001, at Al,
available at 2001 WLNR 11233322.
2. Brown et al., supra note 1; Lynda Gledhill et al., Truck Rams Capitol, S.F. CHRON., Jan. 17,
2001, at Al, available at 2001 WLNR 5737123.
3. Tamaki & Ingram, supra note 1.
4. Brown et al., supra note 1 (internal quotation marks omitted).
5. See id.
6. See Sam Stanton, Tapes Tell Story of Terror, Duty in Capitol Crash, SACRAMENTO BEE, Jan.
20, 2001, at Al. available at 2001 WLNR 11229238.

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