Is the administration of President Obama (D) properly addressing drug violence in Mexico?

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Issues & Controversies MEXICAN DRUG WARS Is the administration of President Obama (D) properly addressing drug violence in Mexico? Issue Date: May 22, 2009 SUPPORTERS ARGUE The administration has taken all the steps it can to contain Mexican drug violence. The U.S. gun lobby would block attempts to reinstate the assault weapons ban, and militarization of the border would be unwise, as armed patrols could endanger the people who live there. Legalizing drugs would also be a bad idea, since it would likely increase the number of users in the U.S., and the drug cartels might simply move into other rackets rather than abandoning violence. OPPONENTS ARGUE The current approach is not sufficient. The United States should reinstate the expired assault-weapons ban to prevent drug traffickers from buying guns in the United States and smuggling them into Mexico. It should deploy troops to the U.S. side of the border, in case the violence spills over. It should also seriously consider legalizing drugs at least marijuana to diminish the violence associated with drug trafficking. Jesus Alcazar/AFP/Getty Images Mexican federal police patrol Ciudad Juárez, which has become the epicenter of violence in the ongoing Mexican drug wars.

The U.S.-Mexican border is one of the world's busiest, with hundreds of thousands of legal crossings every day. Alongside the legitimate traffic of people and goods, however, is an illegal trade estimated by the U.S. government to be worth tens of billions of dollars a year. Drug traffickers smuggle their products from Mexico into the U.S., while money earned from those sales flows in the opposite direction. The trafficking is controlled by powerful Mexican drug cartels. In recent years, those cartels have been fighting both each other and the Mexican authorities, who under President Felipe Calderón Hinojosa have launched a major crackdown on the drug trade. Many observers have characterized the level of violence in Mexico over the past few years as an outright war. Northern cities along the U.S. border have been particularly hard hit, as drug cartels battle for control of the points of entry to the U.S. drug market. Kidnappings, brutal murders and assassinations of government officials, soldiers and police have become common. The drug cartels have developed their own paramilitary units, and are often as well-armed as the government forces they are fighting. The U.S. has sought to assist Mexico in combating drug traffickers through a security-related aid package known as the Mérida Initiative. That aid is being doled out by Congress gradually, however, and the Mexican government has expressed concern that it is not arriving fast enough for Mexico to maintain the upper hand against the cartels. It has also complained of lax gun laws that allow drug traffickers to buy guns easily in the U.S. and smuggle them across the border into Mexico. In addition, the Mexican government has charged that the U.S. should do more to address the role that Americans' demand for drugs has played in the current surge of violence. It was to address such concerns that President Obama (D) visited Mexico in April 2009 to meet with Calderón. He pledged to expedite $700 million in aid, much of it military- and security-related, under the Mérida Initiative. In addition, Obama committed the U.S. to ratifying an international treaty that would improve the tracking of guns across international borders. Critics of the plan say that Obama should have committed to reinstating the U.S. ban on guns with military-style features, known as assault weapons, arguing that such weapons often make their way into the hands of drug traffickers. Other critics take a completely different view, arguing that the Obama administration went too far in pledging to ratify the international agreement on arms smuggling, which they charge could be misused to deprive U.S. citizens of their constitutional gun rights. Still others call for military troops to be deployed to the U.S. side of the border to help stop smuggling and the overflow of violence from the Mexican side. Additional critics call for the U.S. to explore drug legalization as a way to take the drug trade out of the hands of criminals and reduce violence. Supporters of the administration's approach counter that reviving the assault weapons ban is likely to be politically untenable due to the power of anti-gun control groups, so it is better to concentrate on other ways to keep assault weapons and other arms from flowing into Mexico. At the same time, they stress the need for authorities to better track U.S. guns used in Mexico, which they say would have no negative effect on U.S. gun owners. While the Obama administration has not ruled out the possibility of deploying National Guard troops to the border, those who agree with its current decision not to do so say that militarizing the U.S. border would be unnecessary and a mistake. As for drug legalization, those who oppose it say it would increase drug use in the U.S. without reducing the violence in Mexico, since the drug cartels would likely either move into other criminal rackets or find markets for illegal drugs in other countries.

Drug Violence on the Rise in Mexico While drugs, particularly marijuana, have been smuggled across the Mexican border into the U.S. for decades, trafficking increased in the 1980s, partly as an unintended consequence of the U.S. "war on drugs." In the 1970s and early 1980s, cocaine smugglers usually transported the drug from South American countries such as Colombia and Bolivia where it was processed from coca leaves into the U.S. by way of the Caribbean and South Florida. By the mid- 1980s, however, the U.S. was devoting more resources to intercepting cocaine shipments in South Florida, making Mexico a more attractive route for smugglers. The length of the U.S.-Mexican border (nearly 2,000 miles) and the volume of legitimate commerce and travel across it particularly following passage of the North American Free Trade Agreement (NAFTA) in the 1990s have made it impossible for U.S. officials to catch more than a small portion of the smuggled drugs. Although precise figures are difficult to calculate, according to estimates by the Government Accountability Office (GAO), around 90% of the cocaine sold in the U.S. in 2007 came from Mexico, up from around 66% in 2000. Sizeable portions of the marijuana and heroin used in the U.S. are also trafficked through Mexico, along with methamphetamine, commonly referred to as meth. A highly addictive stimulant, meth exploded in popularity in the U.S. during the 1990s and early 2000s. The meth trade differs from the cocaine trade in that meth is actually

manufactured in Mexican laboratories, rather than being trafficked through Mexico from South America. There has long been some level of violence associated with the smuggling of drugs from Mexico. One particularly notorious case occurred in 1985, when an agent of the Drug Enforcement Administration (DEA), Enrique Camarena, was kidnapped and murdered by drug traffickers. U.S. authorities suspected some of their Mexican counterparts of hindering the search for his body and covering up evidence. In recent years, however, violence connected to the Mexican drug trade has increased tremendously. In December 2008, the office of the Mexican attorney general reported more than 5,000 drug-related killings so far that year, a number that was reported to have increased to around 6,000 by year's end. That was more than double the number from the previous year, which at that point had been the highest yearly murder total in modern Mexican history. Many of the recent murders were of drug traffickers, while others were assassinations of police officers, soldiers and even politicians. A minority of the killings were of civilians, including the murders of some journalists. [See State Department Travel Alert on Mexican Drug Violence (sidebar)] In addition to the number of murders, another shocking aspect of Mexican drug violence has been the brutal way in which people have been killed. Drug traffickers have used sophisticated weaponry, including high-powered guns and grenades. Many of the victims have shown signs of having been tortured before being killed. In some cases, victims have been beheaded. Many of the more gruesome murders have seemed designed to intimidate rivals and the government. Mexican border cities, particularly Ciudad Juárez, which lies just across the border from El Paso, Texas, have seen the worst drug violence. In February 2009, Juárez's police chief stepped down after drug traffickers began assassinating police officers and threatened to continue doing so until he resigned. Targeted by traffickers, the city's mayor, Jose Reyes Ferriz, was forced to move with his family to El Paso and cross the border each day to work in Juárez. Many Juárez businessmen live in El Paso and commute each day as well. Thousands have died in the recent drug-related fighting in Juárez alone, and thousands of Mexican troops have been deployed there in an attempt to curtail the violence. While nearly all of the violence connected with the Mexican drug wars has thus far been confined to Mexico itself, there have been some concerns that it could spread into the U.S. Violence in U.S. cities along the Mexican border is still far lower than in Mexican cities such as Juárez, but law enforcement officials estimate that Mexican drug cartels have distribution operations in 230 U.S. cities in states as far north as Alaska. A 2009 report by the National Drug Intelligence Center calls the cartels "the greatest organized crime threat to the United States." There have been a number of recent violent incidents in different parts of the U.S. that authorities suspect are connected to the Mexican drug trade. Examples include a series of home invasions and kidnappings in Arizona, a group of five men found dead near Birmingham, Ala., and a man found confined in a basement by suspected drug traffickers near Atlanta, Ga. Experts suggest a few reasons for the recent increase in violence. One of those is a battle between various cartels for control of the drug trade. The fighting partly results from the growth of the Mexican drug trade since the mid-1980s. That prompted the rise of multiple large cartels, particularly following the 1989 arrest of Miguel Ángel Félix Gallardo, who was eventually imprisoned for offenses relating to the murder of DEA agent Camarena in 1985. Félix had controlled a large share of the drug trade from his base in the city of Tijuana in northwestern Mexico, and his arrest led to the division of his empire. Much of the recent violence has resulted from a war for control of drug routes between three of the biggest cartels the Gulf Cartel, the Sinaloa Cartel and the Juárez Cartel as well as an internal conflict within the Tijuana Cartel. Another reason for the fighting is that the ability of the various cartels to commit violence has grown over time. The cartels have begun to recruit former soldiers and police, some of them from elite units originally trained in the U.S., to carry out attacks. Those recruits join paramilitary groups that have brought more sophisticated tactics to drug violence. Two of the most notorious paramilitary units are Los Zetas, associated with the Gulf Cartel, and Los Negros, associated

with the Sinaloa Cartel. [See Some Mexican Drug Trafficking Groups (sidebar)] A third factor behind the upturn in violence has been the strong stand that recent Mexican presidents have taken against the cartels. Both Ernesto Zedillo Ponce de Léon, who took office in 1994, and Vicente Fox Quesada, whose term began in 2000, deployed the military to fight drug traffickers. Those efforts have intensified under Calderón, who took office in 2006 and deployed tens of thousands of military troops and federal police officers against the cartels, while undertaking an ambitious effort to reform corrupt public institutions that aid them. That has intensified violence by the cartels against the military, the police, the judiciary and the government. Some analysts also point to more specific unintended consequences of Mexico's anti-drug measures, such as the purging of corrupt police officers and soldiers. Many of those who were dismissed have joined the paramilitary forces of the drug cartels. The U.S. has encouraged Mexico's fight against drug traffickers and has provided assistance. In June 2008, Congress approved the Mérida Initiative, a plan resulting from discussions between Calderón and President George W. Bush (R, 2001-09). The initiative provides Mexico with $1.4 billion over three years for military equipment, training, infrastructure upkeep and political reform aimed at combating drug trafficking. While it approved of the plan, the Mexican government argued that the U.S. needed to do more to curb demand for drugs within its own borders and to keep U.S. guns out of the hands of the drug cartels. U.S. Addresses Mexican Drug Violence The rising drug violence in Mexico has coincided with Obama's election and the beginning of his term. A November 2008 report by the Defense Department warned that Mexico was at risk of "rapid collapse," while the State Department issued a travel alert in February 2009 warning visitors to take precautions due to the ongoing violence there. Obama has indicated that he plans to make the issue a high priority during his presidency. In April, he visited Mexico and met with Calderón. In general, Obama echoed sentiments expressed by Secretary of State Hillary Rodham Clinton during her visit to Mexico the month before, in which she said the U.S. and Mexico have a "co-responsibility" for the problem of drug violence. Obama's plan to deal with the violence included assurances that the aid already pledged through the Mérida Initiative would arrive quickly. The administration pledged $700 million in security and related assistance, although much of it was covered under the Mérida Initiative. The administration also changed the legal status of cartel members in the U.S. in order to allow their assets to be seized. More controversially, Obama called on the Senate to ratify the Inter-American Convention Against the Illicit Manufacturing of and Trafficking in Firearms, Ammunition, Explosives and Other Related Materials, better known by the Spanish acronym CIFTA. That treaty requires participating nations to strictly monitor the import and export of firearms, and to improve the sharing of information on weapons between agencies in different countries, in order to cut down on weapons smuggling. The U.S. had signed the treaty, along with 33 other countries in the Western Hemisphere, in 1997, but the Senate has never ratified it. Some U.S. opponents of gun control were against the U.S.'s being a party to a treaty that they said could endanger the right to bear arms under the Second Amendment to the U.S. Constitution. The Obama administration argued that ratifying the treaty was necessary because of the large quantities of guns smuggled from the U.S. into Mexico, where gun laws are much more stringent. Mexican authorities often request that their U.S. counterparts run traces on weapons recovered in Mexico. In cases when such traces have been conducted, 90% of the traced weapons have been found to have originated in the U.S., according to federal officials. U.S. authorities have also uncovered smuggling rings in which guns are purchased legally in the U.S. by people without criminal records and then smuggled across the border into Mexico.

Calderón has called on the U.S. to go further in curtailing gun smuggling. He sought a reinstatement of the U.S. assault weapons ban, which expired in 2004. As a presidential candidate, Obama had favored reinstating the ban. Speaking to reporters in Mexico, however, he backed off that stance, possibly due to the reluctance of Democrats in Congress to support the measure. Others who think the Obama administration has not gone far enough argue that it should pursue the idea of legalizing at least some drugs currently illegal in the U.S. as a way of eliminating the black market for drugs and its attendant violence. The El Paso city council unanimously passed a nonbinding resolution in January 2009 calling for "an honest, open and national debate on ending the prohibition on narcotics." The bill was vetoed by the mayor, however. A small group of U.S. lawmakers from both political parties has also called for marijuana legalization, but Obama does not support such a move. Others say that the U.S. should increase the number of National Guard troops at the border to keep Mexican drug violence from spreading. Texas governor Rick Perry (R), Arizona governor Jan Brewer (R), New Mexico governor Bill Richardson (D) and California governor Arnold Schwarzenegger (R) have called for a deployment of troops, although local officials in some U.S. border cities have called such a move unnecessary. Obama has pledged to deploy more federal border agents to increase security but has not come out in favor of using the military. Critics Fault Approach Critics of the Obama administration's plan object to its approach toward reducing the flow of guns from the U.S. to Mexico. To some critics, the administration's efforts do not go far enough. Those opponents call instead for a renewal of the expired ban on assault weapons. Reinstating the ban would be a more effective way to prevent military-style weapons from entering Mexico and being used to commit violence there, they argue. "It must be said that since the ban expired in 2004, our seizures of assault weapons in Mexico have gone through the roof," says Arturo Sarukhan, Mexico's ambassador to the U.S. "There's a direct relationship between the expiration of the ban and the increase in assault

weapons coming into Mexico and being seized by Mexican authorities." The fact that the administration refuses to pursue the option of reinstating the ban testifies to the enormous political clout of the U.S. gun lobby, critics assert. Groups such as the National Rifle Association (NRA) have enough power to pose a threat to the reelection of politicians who oppose gun rights, they say, so few politicians are willing to do so. "The gun lobby and the firearms industry should reassess their policies concerning safety and accountability at least on assault weapons and ease their pressure on acquiescent politicians who fear NRA disapproval at election time," writes former president Jimmy Carter (D, 1977-81). An entirely separate group of critics faults the administration for doing too much rather than too little about gun smuggling. The role of U.S. guns in Mexican violence tends to be exaggerated, they claim; the 90% statistic is only for guns that Mexico asks the U.S. to trace. Many of the weapons recovered in Mexico are military rifles or rocket-propelled grenade launchers that did not originate in the U.S., they say. In light of that, opponents contend, it is unnecessary for Congress to ratify CIFTA, which could infringe on the constitutional right of Americans to own guns. An NRA press release on CIFTA states that despite assurances to the contrary, "the NRA knows that anti-gun advocates will still try to use this treaty to attack gun ownership in the U.S. Therefore, the NRA will continue to vigorously oppose any international effort to restrict law-abiding American gun owners." Other critics say the administration has not done enough to explore the idea of legalizing drugs, at least in the case of marijuana. Were marijuana legalized, it would be taken out of the hands of traffickers, they argue, transforming it from a high-priced commodity fought over by cartels to a more ordinary product. Marijuana does not pose the serious health risks that other drugs do, they say, so legalizing it would not further strain the health care system. Furthermore, critics suggest that taxing sales of legal marijuana might generate considerable revenue for the U.S. government. "The evidence is clear; legalizing marijuana will reduce its price and the violence surrounding it," says Dan Bernath of the Marijuana Policy Project, a group that supports legalization. Other critics have urged the administration to deploy National Guard troops to the Mexican border. Such a move would make the region more secure, opponents of the current plan say. They argue that objections to troop deployment are overblown; under the proposal put forward by the four border-state governors, for instance, the National Guard would simply be supporting the federal agents in the area. They would likely perform fairly uncontroversial tasks, such as providing transport, as well as communications and intelligence analysis, the governors maintain. Supporters Defend Efforts to Halt Violence Supporters of the Obama administration's approach to stemming the violence in Mexico argue that to stop the smuggling of U.S. guns across the Mexican border, the U.S. must take some commonsense measures to address the problem. They support, for example, the ratification of CIFTA in order to control the flow of guns into Mexico. "Our inability to prevent weapons from being illegally smuggled across the border to arm these criminals causes the death of police officers, soldiers and civilians," Clinton said during her March 2009 visit to Mexico. Supporters maintain that opposition to CIFTA from gun rights groups is misguided. In reality, they say, the treaty would pose no threat to people who buy and own guns in the U.S., a fact that is clearly stated in the text of the agreement. The purpose of CIFTA is not to restrict gun ownership in the U.S., but rather to keep guns from illegally crossing borders and to trace the ones that do, they contend. The treaty "is designed to help U.S. law enforcement track abuses of firearms of criminals back to the last lawful sale so they can determine what went wrong," says Jonathan Winer, who as deputy assistant secretary of state under President Bill Clinton (D, 1993-2001) oversaw CIFTA negotiations. "It is completely consistent with all U.S. laws and does not ever impose a foreign law on a U.S. person who has abided by U.S. law," he explains.

At the same time, proponents say, reinstating the assault weapons ban would probably not be feasible. The Obama administration has indicated that it seeks to work toward curbing the use of assault weapons in Mexican drug violence while not necessarily reviving the ban. Speaking to reporters in Mexico, Obama elaborated: I continue to believe that we can respect and honor the Second Amendment rights in our Constitution, the rights of sportsmen and hunters and homeowners who want to keep their families safe to lawfully bear arms, while dealing with assault weapons that, as we know, here in Mexico, are helping to fuel extraordinary violence. Now, having said that, I think none of us are under the illusion that reinstating that ban would be easy. Supporters also express skepticism that drug legalization would be a viable solution to the drug war in Mexico. For one thing, they say, legalization would carry a heavy cost. If drugs such as cocaine, meth and heroin were legalized, crime in the U.S. committed by people under the influence of those drugs which can impair judgment and reasoning and prompt addicts to commit crimes in order to obtain more drugs would likely increase, they warn. Even in the case of a less harmful drug such as marijuana, legalization would likely lead to more widespread impairment that could be dangerous, they charge. Legalizing drugs would likely mean that they would continue to flow into the U.S. from Mexico, albeit legally, they argue. "Legalizing drugs is the worst thing we could do for President Felipe Calderón and our Mexican allies," writes John Walters, who served as director of the Office of National Drug Control Policy under President George W. Bush. "It would weaken the moral authority of his fight and the Mexicans would immediately realize that we have no intention of reducing consumption." In addition, supporters say, Mexican drug cartels would be unlikely to simply disappear as soon as drugs were legalized. They have become well-established enough that they could probably easily branch out into other illegal activities, such as extortion, supporters argue. The illegal drug trade might even continue, they say, with the cartel's illegal drugs being consumed domestically and in foreign countries other than the U.S., without the promised reduction in violence. Supporters of the administration's approach also question the calls for troops to be sent to the border. Although there has been increased crime in some areas on the U.S. side of the border, they say, overall it has not been pronounced. In fact, they note, the four largest Texas cities along the Mexican border Laredo, McAllen, Brownsville and El Paso, the latter directly across from the intensely violent Mexican city of Juárez report no significant increases in crime, and are ranked among Texas's safest cities. Deploying troops to the area would be unnecessary, proponents say. Deploying troops would also carry its own risks, supporters of the current approach suggest. They point to an incident that occurred in 1997, when Marines on an antidrug mission in Texas killed a teenager they mistook for a drug trafficker. The teenager was herding goats and carrying a rifle to protect them from predators, often found along rural parts of the border. Overall, supporters say, it is better to avoid militarizing the U.S.-Mexican border. "Soldiers are trained to be weapons of war," says El Paso mayor John Cook, himself a veteran. "I'm all for putting more boots on the ground, but they need to be the right kind of boots." U.S., Mexico Share Common Goal Mexican officials have generally expressed satisfaction at the Obama administration's response to the crisis of drug violence in Mexico. Although most had been pleased with the Bush administration's Mérida Initiative, some had felt that it was not a serious enough approach to the problem. However, even with Obama in office, there have been some minor disagreements between the two countries on the issue. For instance, the Mexican government took exception to Mexico being described by some U.S. officials as being on the brink of becoming a "failed state," a criticism Mexican officials

feared would hurt their tourism industry. Mexico has also expressed concern that the Mérida Initiative funding is being authorized too slowly by the U.S. Congress. Calderón's administration has argued that it needs to receive the money sooner to effectively fight the drug cartels, which have billions of dollars at their disposal. Another issue for the Mexican government is whether the U.S. feels it has a personal stake in helping Mexico control drug violence. Recent polls seem to indicate, however, that there is a significant level of concern in the U.S. over the threat of violence spreading across the Mexican border. In addition, the Obama administration has acknowledged the role that the U.S. plays in the violence, both in terms of the flow of U.S. guns into Mexico and the fact that U.S. demand for drugs fuels the Mexican drug trade. Whether the U.S. and Mexico, working together, can eliminate the violence associated with that trade remains to be seen. Discussion Questions 1) Do you think the U.S. should reinstate the assault weapons ban that expired in 2004 as a way to reduce drug-related violence in Mexico? Why or why not? 2) How much of a factor do you think the availability of firearms in the U.S. is in Mexican violence? 3) Should the U.S. military be deployed to guard the U.S.-Mexico border and support border agents? Explain your position. 4) Do you think that the legalization of some or all drugs in the U.S. would be a viable way to reduce violence in Mexico associated with the drug trade? Why or why not? 5) Use the Internet to research a city or state in Mexico and learn how drug violence has affected it. In what ways does the violence change everyday life for people there? Bibliography Archibald, Randall. "Mexican Drug Cartel Violence Spills Over, Alarming U.S." New York Times, March 23, 2009, nytimes.com. Carter, Jimmy. "What Happened to the Ban on Assault Weapons?" New York Times, April 27, 2009, www.nytimes.com. Gleeson, Michael. "Pot Legalization Favored By Some to Stem Violence." The Hill, April 19, 2009, www.thehill.com. Johnson, Alex. "In Mexico's Drug Wars, Fears of a U.S. Front." MSNBC.com, March 9, 2009, www.msnbc.msn.com. Mason, Jeff. "Obama Backs Treaty to Curb Flow of Guns over Border." Reuters, April 16, 2009, www.reuters.com. Mohammed, Arshad. "U.S. to Blame for Much of Mexico Violence: Clinton." Reuters, March 25, 2009, www.reuters.com. Smith, Jordan. "Reefer Madness: Don't Talk About It." Austin Chronicle, January 30, 2009, www.austinchronicle.com. Tedford, Deborah. "Mexico Violence Not Spilling into Texas Border Cities" National Public Radio, April 30, 2009, www.npr.org. Verini, James. "Arming the Drug Wars." Portfolio.com, June 16, 2008, www.portfolio.com. Wallace-Wells, Ben. "How American Lost the War on Drugs." Rolling Stone, December 13, 2007,

www.rollingstone.com. Walters, John. "To Legalize or Not." Wall Street Journal, April 25, 2009, online.wsj.com. Wilkinson, Tracy. "Mexico, Awaiting Obama, Hopes for Change." Los Angeles Times, April 16, 2009, www.latimes.com. Wilson, Scott. "For Obama, Calderón, a Meeting of Minds." Washington Post, April 17, 2009, www.washingtonpost.com. Additional Sources Additional information about the Mexican drug wars can be found in the following sources: Payan, Tony. Three U.S.-Mexico Border Wars: Drugs, Immigration and Homeland Security. Westport, Conn.: Praeger Security International, 2006. Wald, Elijah. Narcocorrido: A Journey into the Music of Drugs, Guns and Guerillas. New York: HarperCollins Publishers, 2002. Contact Information Information on how to contact organizations that are either mentioned in the discussion of the Mexican drug wars or can provide additional information on the subject is listed below: Mexican Embassy to the United States 1911 Pennsylvania Avenue Washington, D.C. 20006 Telephone: (202) 728-1600 Internet: portal.sre.gob.mx/usa National Rifle Association 11250 Waples Mill Road #1 Fairfax, Va. 22030 Telephone: (800) 672-3888 Internet: www.nra.org U.S. Drug Enforcement Administration Mailstop: AES 8701 Morrissette Drive Springfield, Va. 22152 Telephone: (202) 307-1000 Internet: www.dea.gov Keywords For further information about the ongoing debate the Mexican drug wars, search for the following words and terms in electronic databases and other publications: Ciudad Juárez

Drug trafficking Felipe Calderón Hinojosa Mérida Initiative Mexican drug cartels Citation Information Mexican Drug Wars. Issues & Controversies. Infobase Learning, 22 May 2009. Web. 14 May 2016. <http://icof.infobaselearning.com/recordurl.aspx?id=1660>. Copyright 2016 Infobase Learning. All Rights Reserved.