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252
More info: https://chicagology.com/notorious-chicago/stvalentinesmassacre/

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[–] 0 pt

I propose that the current victims of homicide in Chicago, by number and by description as bystanders, meet the definition of wholesale slaughter. As such, they are newsworthy and deserving to be called victims of massacre.

That they are not so described implies that the distinction is more than academic disagreement on usage; e.g. I believe the term 'mutual combatants' was created to promote this falsehood.