TASHIMA, Circuit Judge:
In May 2001, several radical environmentalists decided to take a stand against genetic engineering. They did not protest; they distributed no literature. Instead, they opted for a more direct approach: they selected two targets that they (erroneously) believed were engaged in genetic engineering, and burnt them to the ground.
One of the targets was the office of Dr. Toby Bradshaw, a professor at the Center for Urban Horticulture at...
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