fault of "bad apple" insurance companies rather than his Healthcare law. Of policing The bad apples metaphor has been used by pro-police politicians, municipalities, and police themselves to defend police organizations when police officers are criticized for alleged misconduct. The metaphor communicates that the few criticized officers do not reflect the performance and behavior of the rest. Pro-police officials were first recorded as using the metaphor following the beating of Rodney King and it was used following the shootings of Michael Brown, Alton Sterling, Philando Castile, Breonna Taylor, and the murder of George Floyd. U.S. President Donald Trump used the bad apples metaphor to defend police in a Dallas speech in June 2020, claiming that there are bad apples in every organization and there remains a need for police to protect citizens. In his first presidential debate with Donald Trump on September 29th, 2020, Joe Biden used the bad apples metaphor to defend policing when asked about racial inequality in terms of the justice system, claiming that the vast majority of police officers are "good, decent, honorable men and women". Critics of policing have often rejected use of the metaphor, arguing that policing is a fundamentally broken and racist system. They claim that policing is flawed beyond repair, citing black people being disproportionately more targeted by police than white people and referencing that the police originated from slave patrols. They say that existing police forces must be abolished since attempts at reform are ineffective. A common counter metaphor used by critics such as Rashawn Ray is that the metaphorical apple tree that officers come from is rotten to its roots and must be replaced. Anarchist author Kristian Williams claimed in his book, Our Enemies in Blue: Police and Power in America, that the bad apples argument is a way for police departments to displace blame onto a few officers to avoid criticism and actually changing as a whole. Critics of the police also accuse officers in general of being aware of who "bad apple" officers are and being complicit with them, giving as examples the three other officers present not stopping Derek Chauvin from murdering George Floyd and that 57 Buffalo officers resigned after two officers were suspended for shoving a 75-year-old man. Harry Litman, a US attorney who has worked with police, has said that it is difficult for police departments and other officers to remove "bad apple" officers