2. Any person who brazenly violates the code of civility and decorum of the U.S. House of Representatives, especially elected officials.
3. Rep. Joe Brown of South Carolina, who yelled "You lie!" at our first African-American President during his speech on health care to Congress on Sept. 9, 2009. (Brown's contention that the proposed health care reform bill would somehow insure illegal aliens was later deemed false on both FactCheck.org and Politifact.org.)