By the mid-2000s, the phrase began to appear in print, again linked to young people's premature, violent deaths. In March 2003, under the headline "Rest In Power, Rachel Corrie", "In These Times" eulogised the death of activist Rachel Corrie at the hands of the Israeli military in Gaza. In a 2005 opinion piece in the "San Francisco Chronicle", Meredith Maran reflected on 19-year-old Meleia Willis-Starbuck, a Dartmouth College scholarship student who was home in Berkeley for the summer when she was shot and killed by an unknown assailant outside her apartment. Writing of the makeshift public altar set up to mourn Willis-Starbuck, Maran wrote, "I've never seen 'Rest in Power' written as a substitute for 'Rest in Peace.'"