The Numerous Federal Legal Definitions of Terrorism: The Problem of too Many Grails
![handle is hein.journals/jleg30 and id is 255 raw text is: THE NUMEROUS FEDERAL LEGAL DEFINITIONS
OF TERRORISM:
THE PROBLEM OF TOO MANY GRAILS
Nicholas J. Perry*
When all who were to take part in the Quest [of the Holy Grail] had taken the oath,
those who were keeping the record found the tally to be one hundred and fifty... .
I. INTRODUCTION
The search for a definition for terrorism has aptly been compared to the quest for
the Holy Grail by King Arthur's Knights of the Round Table, with eager souls set[ting]
out, full of purpose, energy and self-confidence, to succeed where so many others have
failed.,2 Like definitions of terrorism, the Holy Grail assumes many forms.'3 How-
ever, unlike the Grail Quest, where many sought the Grail but only a few knights ac-
complished the quest,4 many searchers located a definition of terrorism. The different
proposed scholarly and legal definitions of terrorism are more numerous than the 150
knights seeking the grail, and definitional consensus has been at least as elusive as the
Grail.
Federal law provides numerous, although fewer than 150, definitions of the term
terrorism.5 This Article examines twenty-two definitions or descriptions of terrorism
* Attorney, Department of Homeland Security, Bureau of Immigration and Customs Enforcement, El
Paso, Texas. B.A. University of Notre Dame, 1990, J.D. North Carolina Central School of Law, 1997. The
opinions contained in this Article are solely the author's and do not represent those of the Department of
Homeland Security, any of its components, or any other of its employees.
1. THE QUEST OF THE HOLY GRAIL 50 (Pauline Matarasso trans., 1969).
2. Geoffrey Levitt, Is 'Terrorism' Worth Defining?, 13 OHIO N.U. L. REV. 97, 97 (1986); OMAR MALIK,
ENOUGH OF THE DEFINITION OF TERRORISM xvii (2000) ([T]he search for a single definition has come to
resemble the quest for the Holy Grail.); James A.R. Nafziger, The Grave New World of Terrorism, 31 DENV.
J. INT'L L. & POL'Y 1, 10 (2002) ([A]n operation definition [of terrorism] remains the Holy Grail of the
terrorism debate.); Henry H. Perritt, Jr., Jurisdiction in Cyberspace, 41 VILL. L. REv. 1, 119 (1996) (Ade-
quately defining 'political terrorism,' however, is the Holy Grail of political violence scholarship.).
3. NEW ARTHURIAN ENCYCLOPEDIA 213 (Norris J. Lacy ed., 1996) (1991); compare A.T. Hatto, Fore-
word to WOLFRAM VON ESCHENBACH, PARZIVAL 7 (A.T. Hatto trans., 1980) ([T]here were stories of as
many different Grails as there were writers or syndicates exploiting the potent name.), with L. Paul Bremer
Ill, Terrorism and the Rule of Law, Address Before the Commonwealth Club of California, San Franciso
(April 23, 1987), in U.S. DEP'T OF STATE, BUREAU PUB. AFF., CURRENT POLICY No. 947 at 2 (There are as
many definitions [of terrorism] around as there are definers.).
4. In some versions of the Grail Quest three knights find the grail, while other versions of the legend
differ on the number and name of the quest achievers. See generally NEW ARTHURIAN ENCYCLOPEDIA, supra
note 3, at 212-13.
5. Although beyond the scope of this Article, there is a similar lack of consensus in international law.
249](ViewImageLocal?handle=hein.journals/jleg30&div=14&collection=&method=preview&ext=.png&size=3)
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The Numerous Federal Legal Definitions of Terrorism: The Problem of too Many Grails
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