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Detention & Habeas Corpus

Further Thoughts on the Court’s Refusal to Hear the Guantanamo Detainee Appeals

*Cross-posted from Balkinization

The Supreme Court this week narrowly declined to hear the habeas appeals of the Guantánamo detainees. The detainees had sought review of the D.C. Circuit's decision detainees in Boumediene v. Bush and Al Odah v. United States, upholding the jurisdiction-stripping provisions of the Military Commissions Act of 2006 (MCA). In a joint statement respecting the denial of certiorari, Justices Stevens and Kennedy explained that the detainees should first exhaust their remedies in the D.C. Circuit available under the Detainee Treatment Act of 2005 (DTA). It is too early to assess the long-term impact of the certiorari denial and, as Marty Lederman points out in his excellent summary similar challenges are expected to reach the Court through DTA petitions. Still, the Court's refusal to hear the cases provides a window into some troubling legacies of the Guantánamo detainee litigation.

Nearly three years have passed since the Court handed down Rasul v. Bush, ruling that Guantánamo detainees have the right to habeas relief and directing district courts to consider their petitions in the first instance. Though the Court also suggested in Hamdi v. Rumsfeld, decided the same day as Rasul, that a lawfully constituted military tribunal might provide this inquiry in the narrow circumstances of a traditional combatant captured on an actual battlefield (citing, for example, standard hearings provided under U.S. army regulations), where no such process was provided, habeas was expected to fill in the gap. Yet, Rasul has become an increasingly distant memory: as much time has passed since Rasul as between Rasul and the arrival of Guantánamo's first prisoners in January 2002. And still no detainee has had anything approaching his day in court.

It is difficult to see a principled basis for exhaustion, especially after more than five years of detention without charge. As the dissent from the certiorari denial explained, the D.C. Circuit has already held that the detainees have no constitutional rights, period. So, until that ruling is reversed by the Court, the underlying Combatant Status Review Tribunal (CSRT) process that the D.C. Circuit reviews under the DTA need not comply with basic constitutional safeguards, including the right to see the government's evidence, to the assistance of counsel, to be free from detention based on evidence gained through coercion, and to compel production of exculpatory evidence.

The Court's refusal to hear the detainee cases highlights the continuing absence of meaningful review in the new system of indefinite executive detention that has taken root in the so-called "war on terror." The CSRT, recall, was concocted nine days after Rasul to help avert district court hearings. It is so deeply flawed that it would pose a challenge for any court to uphold under even a crimped due process analysis. (Since the D.C. Circuit found the detainees had no Fifth Amendment rights, it was relieved from having to try.). The DTA and MCA, in turn, sought to eliminate the basis for those hearings under the habeas statute, described in Hamdi as providing a "skeletal outline" for adjudicating the factual and legal basis for a prisoner's confinement. What habeas provides – and what the administration most fears – is the possibility that a federal judge will examine whether a detainee is actually an "enemy combatant" (even under the CSRT's virtually limitless definition), an inquiry that, in many cases, would require assessing whether any statements were wrung by coercion from the petitioner or from another detainee.

The Court's refusal to hear appeals in Boumediene and al Odah, then, marks merely the latest chapter in the United States' ongoing failure to provide a fair and lawful process to those it imprisons. It is this failure that has made Guantánamo a lightening rod for criticism and prompted calls for its closure at home and abroad. (Matters reached a new low in recent weeks with the nakedly political deal struck in the David Hicks case, the first "conviction" by Guantánamo's military commission, and by the release of CSRT records redacting allegations of torture in the name of "national security"). To be sure, the courthouse doors still remain open to the Guantánamo detainees. But it is difficult to see what it is to be gained by subjecting detainees to more delay and to a process intended, as one MCA supporter put it, to "get the lawyers out of Guantanamo." Guantánamo was designed by the Executive to create a prison beyond the law. The record of the other two branches in coming to grips with the fall-out from this ill-advised decision has been disappointing at best, resulting in the human rights debacle that Guantánamo has come to symbolize.

Tags: Justice, Liberty & National Security, Detention & Habeas Corpus

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Supreme Court Rewards Administration’s Delay and Obfuscation Strategy on Guantanamo

*Cross-posted from The Huffington Post

The Supreme Court this morning said that it would not review the case of the Guantánamo detainees. Three Justices (Souter, Breyer, and Ginsburg) voted to grant the detainees a hearing. But you need four votes for a case to be heard (and five votes to win). Justices Kennedy and Stevens issued a statement saying there was no reason to set aside traditional rules that require "the exhaustion of available remedies as a precondition to accepting jurisdiction over applications for the writ of habeas corpus." What this means is that the detainees--many of whom have been detained for more than five years without any form of independent review--have been denied an opportunity to expeditiously vindicate their constitutional rights.

Generally, when the Court decides not to hear a case, this has little consequence. That is not the case here. The Court's decision not to hear this case is a major blow to human rights values. It leaves on the books a wretchedly bad (and intellectually dishonest) opinion from the D.C. Circuit Court of Appeals, and rewards the Administration's deeply nefarious strategy of delay and obfuscation around Guantánamo.

Readers who haven't been following the rather complex chain of litigation around Guantánamo may find some background helpful. The first group of Guantánamo detainees arrived in Cuba in January 2002. Some had been picked up off the battlefield in Afghanistan, but many others had been handed in by Afghan or Pakistan allies, keen for the $5000 bounty offered by the United States. None of them had been screened through the battlefield hearings required by the laws of war and the Geneva Conventions.

The Center for Constitutional Rights and a small group of private lawyers filed habeas suits on the detainees' behalf, arguing that they had a right to challenge the factual and legal basis of their detention in federal court. The government, perhaps aware that many of its detention decisions could not be defended, threw up a series of barriers, arguing principally that Guantánamo lay outside the jurisdiction of the federal courts. In 2004, the Supreme Court rejected this argument, and it looked like the detainees would get their day in court.

But the Government hadn't emptied its quiver. In short order, it managed to finagle the passage of first the Detainee Treatment Act and then the Military Commission Act, both of which purported to strip the federal courts of power to hear the cases. In February this year, the Court of Appeals in Washington DC held that the Military Commissions Act had indeed done so. In an opinion that rested on a distorted and partial view of history, the D.C. Circuit held that the Guantánamo detainees had no constitutional rights. Hence, it dismissed their five-year-old case.

That was the decision that the Supreme Court could have taken for review. But didn't. The result? The detainees can have recourse to a narrow and arguably insufficient channel of review left open by the Detainee Treatment Act: But they must start from scratch with no guarantee that the channel of review available will be meaningful--or a sham.

(The question of how future challenges will proceed is complex. The government successfully argued that review be confined to an appellate court, which lacks the power to find facts and depends on the Army for building a record. The best case scenario might be that the Court of Appeals requires the military to restructure their fact-finding procedures. But this is a long shot).

This is bitter news. It is deeply unfair and inflicts grave harms today on the detainees. Five years after their first detention, many of the detainees, I am told, are at the end of their psychological tethers. There have been multiple suicide attempts. Given the endless and the uncertainty of their confinement, this is hardly surprising. Detention without end, often for no reason at all, is a kind of torture (even if it doesn't meet the strict legal definition of that term).

I'm happy to field questions about the decision.

Tags: Justice, Liberty & National Security, Detention & Habeas Corpus, Domestic Counterterrorism

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The Cover-Up Continues

*Cross-posted from The Huffington Post

The United States this week released the transcript of the military hearing for self-proclaimed 9/11 mastermind Khalid Shaikh Mohammed. Initial accounts in the New York Times and Washington Post described the "confession of a top leader" and detailed Mr. Mohammed's participation in a laundry list of terrorist plots. Yet, the confession of Mr. Mohammed (or "KSM" as he is better known) comes as no surprise. He has long claimed a leadership role in al Qaeda and in the 9/11 attacks, as the 9/11 Commission documented. The real story is not what KSM said but how much the administration is fighting to keep secret.

Although he has been in U.S. custody for four years, KSM is one of Guantánamo's newest detainees. In September 2006, he and thirteen, other "high-value" terrorist suspects were transferred from secret CIA prisons or "black sites" to Guantánamo. These CIA prisons were established to implement various "enhanced interrogation techniques," the post-9/11 euphemism for torture, and to preclude any possibility that a court would review the actions of Executive branch officials. As Ron Suskind recounts in The One Percent Doctrine, interrogators subjected to KSM to water-boarding, a technique that simulates drowning, and threatened to rape and kill his family. Other "enhanced interrogation techniques" included "cold cell," where prisoners are left to stand naked in a cell kept near 50 degrees while they are doused with cold water, and "long time standing," where prisoners are forced to stand, handcuffed and with their feet shackled to an eye bolt in the floor for more than 40 hours.

The transfer of the 14 "high level" suspects to Guantánamo was prompted by the Supreme Court's June 2006 decision in Hamdan v. Rumsfeld. Until Hamdan, the administration maintained that detainees were all "unlawful combatants" in a global "war on terror," and thus fell outside any legal protections. In Hamdan, the Supreme Court rejected that position, ruling that al Qaeda members and other that suspected terrorists are protected at least by Common Article 3 of the 1949 Geneva Conventions. This provision establishes a baseline of protections for all detainees, prohibiting torture, cruel treatment and other abuse. And, the federal War Crimes Act made officials criminally liable for breaches of Common Article 3. Faced with a rejection of the legal building-block of its CIA "black sites," as well as the potential liability of government interrogators, the President announced in a televised speech to the Nation that he was transferring the remaining secret prisoners to Guantánamo. He then engineered passage of the Military Commissions Act of 2006, which amended the War Crimes Act to help shield CIA and other officials from prosecution for past abuses while stripping the federal courts of habeas review over the cases of detainees held as "enemy combatants" at Guantánamo and elsewhere.

Since then, secrecy has dominated the treatment of KSM and the other ex-ghost detainees, just as it has pervaded the detention of the more than 700 hundred other individuals held at Guantánamo since January 2002.

To begin with, the Combatant Status Review Tribunal hearings (or "CSRTs") of these detainees are closed to the press. Ironically, the military permitted the press to attend the CSRT hearings for Guantánamo detainees in the past. One would have expected the military to want the hearings of the "biggest fish" at Guantánamo to be open to the public to demonstrate the strength of its evidence. And, it is precisely in such cases, that the public's interest to know is strongest. But, apparently, that calculus is different when evidence has been gained through torture.

In any event, opening KSM's CSRT to the press would not have solved the problems of excessive secrecy nor of the kangaroo-court nature of the CSRTs themselves where detainees have no lawyer or right to see the evidence against them. KSM's transcript is heavily redacted because his descriptions of torture and mistreatment were all deemed classified. The publicly available record thus contains no discussion of water-boarding, death threats, or other coercion.

This type of excessive secrecy is hardly unique. In another case, the government has sought to bar the detainee (Majid Khan) from discussing his interrogation at a CIA prisons with his own lawyer. Merely talking about torture, the government's argument goes, jeopardizes national security (even though the government's use of coercive interrogation tactics is no longer a secret). Avoiding embarrassment by suppressing discussion and debate about past illegality contradicts the essential principles of openness and accountability upon which a democracy depends.

Yet, there is another, more pernicious consequence to suppressing the truth. KSM explained at his CSRT hearing that he falsely implicated other detainees as a result of his abuse. These statements are corroborated by those of CIA officials who, according to Suskind, say that KSM later recanted prior statements made under duress. Notably, Mohammad al Qahtani, a Guantánamo detainee subjected to prolonged sleep deprivation, sexual and religious abuse, the use of painful stress positions, and other abuses reportedly implicated 30 other detainees during his interrogations. How many detainees are being held based upon statements made by KSM, al Qahtani, and others that were obtained by torture? If the administration has its way, we will never know because CSRT procedures deny detainees the right to see the evidence, call witnesses, or otherwise demonstrate they are being wrongly held based upon information gained by the rack and the screw.

Reliance upon evidence gained by torture violates our most basic principles. As the Supreme Court put it, imprisoning people based upon coerced statements is "offensive to a civilized system of justice." It is also inherently unreliable because we know from centuries of experience stretching back to the middle ages that prisoners make false statements to avoid extreme physical or mental pain. Indeed, that is precisely why U.S. army guidelines - ignored by this administration - prohibit coercive interrogation techniques, explaining that such techniques "induce the source to say whatever he thinks the interrogator wants to hear."

Clearly, the American public cannot expect the administration to come clean about who it is detaining and why. That is precisely the reason federal courts must retain their historic power to inquire into the facts through the Great Writ of habeas corpus. Later this month, the U.S. Supreme Court will decide whether to review a recent decision by a federal appeals court [pdf] in Washington, D.C. upholding the recent elimination of habeas corpus for Guantánamo detainees. Unless these court-stripping provisions are invalidated, and habeas corpus is preserved, America will for the first time have sanctioned imprisonment based upon torture. No nation committed to human rights and the rule of law can accept that result.

Tags: Justice, Liberty & National Security, Checks & Balances, Detention & Habeas Corpus, Domestic Counterterrorism

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Faulty History at the D.C. Circuit

*Cross-posted from Balkinization

The District of Columbia Circuit’s 2-1 decision in Boumediene v. Bush directing dismissal of Guantanamo Bay detainee habeas corpus petitions turned partly on a historical assessment of the scope and meaning of the Great Writ. The judges all agreed that section 7 of the Military Commissions Act of 2006 (“MCA”) eliminated habeas jurisdiction over petitions filed by or on behalf of aliens detained at Guantanamo. Writing for the court, Judge A. Raymond Randolph found that the MCA did not violate the Constitution’s Suspension Clause because, he concluded, the writ of habeas corpus was not available to non-citizens detained outside the sovereign territory in 1789. Dissenting Judge Judith Rogers disagreed, finding that the writ would have been available in a territory like Guantanamo at the time of the nation’s founding. The MCA was void, she concluded, because Congress had eliminated habeas jurisdiction without suspending the writ or providing an adequate and effective substitute.

What role history will play at the Supreme Court remains uncertain. But it is useful to identify some shortcomings in the court’s analysis and in the inferences drawn from the historical record.

To begin with, the D.C. Circuit treated as an open question whether the writ would historically have extended to a territory like Guantanamo, where the United States exercises complete and exclusive jurisdiction and control, but not sovereignty. That question, however, was already answered by Rasul v. Bush (542 U.S. 466 (2004)). There, the Supreme Court concluded that the “[a]pplication of the habeas statute to persons detained at the [Guantanamo naval] base is consistent with the historical reach of the writ of habeas corpus.” Importantly, in Rasul the Court rejected the government’s argument that the writ’s reach at common law turned on territorial sovereignty rather than on “the practical question” of the crown’s control over the particular territory. The Court relied, for example, on King v. Cowle (97 Eng. Rep. 587 (K.B. 1759)), where Lord Mansfield explained that the writ would run to territories “under the subjection of the Crown.”

The D.C. Circuit also misconstrued the historical record. Contrary to the court’s conclusion, and as noted by the dissent, the common law writ was available in territory where the Crown exercised de facto but not de jury sovereignty. In India, English courts issued writs of habeas corpus to non-citizens unlawfully detained by crown officials. Moreover, in India Britain intentionally delayed the assertion of formal sovereignty over crown-controlled territories for decades after judges had begun issuing writs of habeas corpus on behalf of prisoners there to curb arbitrary exercises of power. (Disclosure: I represented a group of historians as amici curiae who argued these issues to the court). What this history shows is that there were no legal black-holes at common law, not that sovereignty was the touchstone, let alone the sine qua non, of habeas jurisdiction.

In fact, in no case before 1789 was the common law writ of habeas corpus held not to extend to territory under the crown’s exclusive control and jurisdiction. To the contrary, courts historically resolved any questions about the writ’s territorial reach in favor of its availability. The default rule in favor of habeas jurisdiction should apply with even greater force where the executive deliberately seeks to create a prison in a territory under its complete and permanent control to circumvent judicial review, as it has done at Guantanamo.

Judge Randolph also ignored the distinction between statutory and common law habeas. Judge Randolph pointed to Habeas Corpus Act of 1679, reasoning that the act’s time-limits for producing a prisoner showed that the writ would not run outside the sovereign territory of the crown. But this statute applied only to criminal cases and did not affect the common law writ which remained available in cases of executive and other non-criminal detention, including detention by the military. No territorial limits were placed on the common law writ’s reach, and it was this writ, not the 1679 act, that traveled to America and was operating in all thirteen colonies that rebelled in 1776. (Judge Randolph’s statement that there is no common law jurisdiction misses the point; as the Supreme Court explained in INS v. St. Cyr (533 U.S. 289 (2001)), the Suspension Clause guarantees statutory habeas jurisdiction at least in all cases where the writ would have been available at common law). In addition, it is ironic indeed to claim that the 1679 act – whose procedural reforms prompted William Blackstone to extol the statute as a “bulwark of individual liberty” – sanctions the creation of lawless enclaves in the twenty-first century. Merely because it might have been impractical to impose the 1679 act’s time-limits on habeas petitions filed by or on behalf of individuals held overseas four centuries ago does not support limiting constitutional habeas jurisdiction today to territory where the United States exercises sovereignty.

The court also mistakenly suggested that the Suspension Clause protects only the writ as it existed in 1789. As Judge Rogers notes, the court ignored the Supreme Court’s repeated statements that the Suspension Clause, at a minimum, protects the writ as it existed in 1789. (Marty Lederman also makes this point in his account of the decision). Judge Randolph thus neglected to consider whether the writ should extend to Guantanamo even if it would not have extended to such a territory in 1789. Assuming there were no common law case directly on point, the availability of habeas at Guantanamo is central to the writ’s core purpose as a safeguard of individual liberty. Legal challenges to executive detention at Guantanamo thus fall squarely within the heartland of habeas protected by the Suspension Clause, direct analogies from history aside.

Because the court found that the detainees had no constitutional right to habeas, it did not consider whether review by the D.C. Circuit of Combatant Status Review Tribunal (“CSRT”) decisions under the Detainee Treatment Act of 2005 could provide the adequate and effective substitute that the Suspension Clause requires. Judge Rogers, however, found this review scheme inadequate and ineffective, even though she rejected the claim that the detainees have rights under the Due Process Clause of the Fifth Amendment, as the district court had held in In re Guantanamo Detainee Cases (355 F. Supp. 2d 443 (D.D.C. 2005)). Judge Rogers thus recognized that Guantanamo detainees possess a core right against executive detention inherent in the common law writ of habeas corpus distinct from rights they may assert under the Fifth Amendment (rights the Supreme Court seemingly acknowledged in footnote 15 of Rasul). Judge Rogers concluded that the DTA’s narrow review of the flawed CSRT process, which lacks any meaningful factual inquiry, cannot provide adequate and effective substitute for common law habeas, a process codified in the habeas statute, 28 U.S.C. 2241 et seq. Indeed, Justice O’Connor described a similar habeas process, distinct from the Due Process Clause, in Hamdi v. Rumsfeld (542 U.S. 507 (2004)), as did Judge Michael Mukasey in Padilla ex rel. Newman v. Bush (233 F. Supp. 2d 564 (S.D.N.Y. 2002)). In short, at common law, prisoners routinely obtained a meaningful judicial inquiry into the factual as well as legal basis for their detention – precisely what the combined effect of DTA review of CSRT decisions precludes.

Ultimately, the most compelling historical argument against the MCA is that the concept of a law-free zone at Guantanamo contradicts the writ’s essence as a check against unlawful executive detention. The notion that the President can maintain Guantanamo as a prison beyond the law based on the legal fine print of sovereignty is antithetical to the basic principles habeas corpus and the Suspension Clause embody. It does not take a historian to recognize this much.

Tags: Justice, Liberty & National Security, Detention & Habeas Corpus

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American Justice on the Line

*Cross-posted from The Huffington Post 

Last week, a district judge in Washington dismissed the case of Guantanamo Bay detainee Salim Hamdan. In June, Hamdan won a landmark Supreme Court decision striking down President's jerry-rigged system of military trials at Guantanamo. Now, thanks to a new law stampeded through Congress in October, Hamdan cannot even get into court. This decision should alarm all Americans who care about their country's most basic rights and values.

The fate of the remaining 400 prisoners at Guantanamo - now entering their fifth year in detention without charge - hinges on how other courts interpret this new law, known as the Military Commissions Act of 2006 ("MCA"). Most significantly, the act purports to eliminate these prisoners' right to habeas corpus simply because the President has concluded they are "illegal enemy combatants." If appeals courts agree with the district judge's decision, these prisoners will face potential life sentences without a judicial hearing, let alone a trial, to determine their guilt or innocence.

The MCA's harm threatens to spill beyond Guantanamo. The President has taken the radical position that he can now deprive non-citizens living in this country of their right to habeas corpus. In his view, the military can snatch any of the millions of immigrants off the streets of the United States at any time and jail them forever without charge or court review. For the first time in the Nation's history, those who live and work among us can be vanished, just like in a Latin American dictatorship.

More though is at stake than the fate of individual detainees. Habeas corpus embodies America's commitment to justice and fairness, essential principles endangered by the siren call of "national security."

Why then does the President want to get rid of habeas corpus? Because for the past five years habeas has provided the one meaningful check on his power to detain and interrogate suspected terrorists outside the law.

Long celebrated as the Great Writ of Liberty, the Framers made habeas corpus "the bulwark" against arbitrary government in our Constitution. The Great Writ has the power to unmask and reveal abuses of power not through lawyers' arguments but through the power of a judge - as the phrase habeas corpus or "you have the body" suggests - to order a prisoner be produced for a hearing to inquire into the facts.

Habeas, then, is not a get-out-of-jail free card. Instead, it protects what most Americans rightly understand as justice: the opportunity for all prisoners to be judged, fairly and openly, in a court of law.

To be sure, the President claims that Guantanamo detainees are "the worst of the worst." But, if that is true, why has the President has not produced any evidence to sustain these allegations? No person detained as an "enemy combatant" has ever testified in a federal court, and the administration has thus far successfully blocked hearings in the hundreds of habeas cases filed since the Supreme Court ruled in 2004 that federal courts must hear the detainees' petitions. Indeed, whenever confronted with the prospect of meaningful court review, the administration has chosen to free prisoners rather than face a judge's scrutiny of its detention operations.

In place of habeas, the administration says determinations must be made by a Combatant Status Review Tribunal ("CSRT"). The CSRT, however, merely rubber-stamps decisions made by the Defense Department, imprisoning people based on secret evidence and evidence gained by torture. According to a recent report by Seton Hall law school, most detainees were found to be "enemy combatants" based on evidence they never saw or had any chance to respond to. Instead of an attorney, detainees were given "personal representatives," military officers who typically meet with them once for 10 minutes before their hearing. In America, a person gets more due process when he contests a parking ticket than a Guantanamo detainee gets to prove his innocence before he is condemned to years, if not decades, of imprisonment.

Often, it is the graphic image that galvanizes the public's attention, whether it is the picture of a human pyramid of prisoners at Abu Ghraib or of Jose Padilla in blacked-out goggles at a South Carolina navy prison. But, perhaps the worst form of torture perpetrated since September 11, and the one habeas corpus is designed to prevent, is indefinite imprisonment without charge. Unlike convicted criminals, individuals detained as "enemy combatants" at Guantanamo and elsewhere have not been tried or sentenced. They do not know when, if ever, might be released or charged with a crime. Instead, they remain in perpetual limbo in an amorphous and never-ending "war on terrorism," without access to the courts and isolated from family and the rest of the outside world.

Fortunately, there is a rising tide of support for habeas corpus from across the political spectrum. Conservative legal scholars have joined liberals in opposing limits on habeas corpus. Former federal prosecutors, including former Attorney General Janet Reno, have also denounced the administration's policy of illegal detentions. Meanwhile, the television program Sleeper Cell has dramatized the creeping horror of time spent in isolation for millions of Americans. There is a growing sense, then, that administration has gone too far, alienating even some of its staunchest supporters, by imprisoning people without access to the courts.

Habeas corpus protects freedom and justice - values that cross party lines. As the Supreme Court explained, habeas helps maintain the "delicate balance of governance" by "serving as an important judicial check on the Executive's discretion in the realm of detentions." With the administration's "war on terrorism" well into its sixth year, it is essential that the courts and Congress preserve this proud legal tradition from extinction.

Tags: Justice, Liberty & National Security, Checks & Balances, Detention & Habeas Corpus, Domestic Counterterrorism

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A Symbol of “Extraordinary Rendition” Returns to the U.S.

*Cross-posted from The Huffington Post

Tomorrow, a German man arrives at John F. Kennedy international airport. This seemingly unremarkable event is in fact a moment of personal bravery that ought to spur national contrition.

Khaled E-Masri, the arriving German national, tried to come to the United States once before. When he arrived, he was hauled aside, imprisoned, and then promptly deported back to his home in Germany.

His crime? Being a danger to the United States? On one of the federal government famous (and multitudinous) watch lists? Hardly. Khaled El-Masri was declined entry because he had been mistakenly kidnapped by the United States in 2003, taken to a U.S. base in Afghanistan, brutally interrogated, and detained long after the government--at its highest levels--knew him to be wholly innocent of any wrongdoing, or even tangential connection to terrorism. Khaled El-Masri was refused entry because he was an embarrassment: A public symbol, renowned across the world outside American borders, of the wretched consequences of America's "extraordinary rendition" policy.

Despite Secretary of State Condoleezza Rice's promise that intelligence errors would be addressed, and when necessary remedied through the federal courts, Mr. El-Masri has been denied any meaningful acknowledgment of his ordeal. While declining to comment on the El-Masri case in particular, the American ambassador to Germany has offered regrets for any mistakes that "may have been made." And the German government reports that American officials tried to buy Mr. El-Masri's silence, rather than acknowledging their terrible incompetence.

The Bush Administration's approach to national security is one of "take no prisoners, have no regrets." Claims of unfettered executive power, after all, fit ill with the mounting evidence of incompetence and sloppiness that the El-Masri case too acutely illustrates.

And since acknowledging its error would undermine its recklessly unilateral vision of national-security policy-making, the Administration is twisting other branches of government to hide its sins.

If Mr. El-Masri is allowed to enter the United States he will have the chance to see his case argued in court. Lawyers from the ACLU who represent Mr. El-Masri will argue on Tuesday before the United States Court of Appeals for the Fourth Circuit that Mr. El-Masri is entitled to a remedy for his nightmare. (Full disclosure: in my capacity at the Brennan Center, I am counsel for a group of retired American diplomats who have filed an amicus brief arguing that the denial of a judicial forum to Mr. El-Masri causes grievous harm to American standing in the world).

The ACLU lawyers in question are superlative--but they face an uphill slog. The District Court denied Mr. El-Masri's case on national security grounds before any discovery had began, and the Government will argue that it was right to do so.

Before the (notoriously conservative) Fourth Circuit, government lawyers will contend that any confirmation or denial by the United States or its officials of the facts in Mr. El-Masri's case will harm the nation's security.

This is despite the fact that Mr. El-Masri has told his tale to the world's press without rebuttal from the United States. It is despite a plethora of physical evidence--including chemicals found in Mr. El-Masri's hair that prove he was taken to Afghanistan and flight logs that confirm his tale. Despite the fact that another prisoner held in Afghanistan has confirmed Mr. El-Masri's story. Despite the fact that several other governments and the intergovernmental Council of Europe are conducting active inquiries into his case. Despite all this, the Government insists that to say one word about this most shameful of public tales would undercut our collective well-being by violating "state secrets."

The "state secrets" argument that the Government makes in the El-Masri case has recently been rejected by three district courts in litigation concerning the NSA wiretapping. In these case, judges pointed out that Government cannot take a fact that is squarely in the public domain and simply recharacterize it as "secret." The same logic should allow Mr. El-Masri his day in court.

Indeed, the "state secrets" privilege has from its inception been more about covering up government malfeasance and incompetence than it has been about protecting national security. Historian Louis Fisher has recently shown that the 1953 Supreme Court case in which the government first successfully pressed the "state secrets" privilege involved no real national security issue: Rather, the privilege was used to conceal government incompetence that would have been the basis of tort liability.

More recently, the Government invoked the state secrets privilege last month in the case of Guantánamo detainee Majid Khan, arguing that Khan not be allowed to talk to his lawyer because he might reveal the techniques used to interrogate him. State secrets, in other words, is a nice euphemism for "how we torture."

Imagine what it takes for Mr. El-Masri to get on a plane to the United States--to the country that tore a months-long hole in his life, that treated him as less than a human being, but something disposable, something close to a nullity. He deserves better than this. He deserves better than a "state secrets" argument that adds insult to the injuries already inflicted, an argument that wrongly discards the human entitlements of Mr. El-Masri, but also treats the American people, and the broader world public, as fools and an irrelevance.

Tags: Justice, Liberty & National Security, Checks & Balances, Detention & Habeas Corpus, Domestic Counterterrorism

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Suspending Habeas Corpus at Guantanamo and Beyond

*Cross-posted from Balkinization

One of the most significant aspects of the Military Commissions Act of 2006 (“MCA”) is its repeal of habeas corpus jurisdiction. Section 7 of the MCA eliminates habeas for an “alien detained by the United States who has been determined by the United States to have been properly detained as an enemy combatant or is awaiting such determination.” Does this provision violate the Constitution’s Suspension Clause?

Challenges to the MCA’s habeas repeal will be addressed in the Guantánamo detainee litigation, where two lead cases are pending before the D.C. Circuit, Al Odah v. United States and Boumediene v. Bush. In Al Odah (captioned in the district court as In re Guantanamo Detainee Litigation), Judge Joyce Hens Green invalidated the Combatant Status Review Tribunal (“CSRT”), established to determine whether Guantánamo detainees were enemy combatants. Judge Green found that the Guantánamo detainees were protected by the Fifth Amendment’s Due Process Clause and that the CSRT violated due process by denying them access to counsel, preventing them from seeing the government’s evidence, and permitting evidence gained by torture. In Boumediene, by contrast, Judge Leon concluded that Guantánamo detainees had no cognizable rights, notwithstanding the Supreme Court’s ruling in Rasul v. Bush, 542 U.S. 466 (2004), that the detainees could challenge their confinement by habeas corpus.

As a threshold matter, precedent supports the conclusion that Guantánamo detainees have a constitutional right to habeas. In Ex parte Bollman, 8 U.S. (4 Cranch) 75 (1807), Chief Justice Marshall suggested that even though judges must have a statutory basis to issue the writ, the Suspension Clause obligates Congress to establish habeas jurisdiction, as Congress did in the Judiciary Act of 1789. The Court revisited Marshall’s statement in INS v. St. Cyr, 533 U.S. 289 (2001), suggesting that statutory habeas jurisdiction is constitutionally compelled by the Suspension Clause.

But even so, do aliens detained at Guantánamo fall within the Suspension Clause’s protections? Rasul suggests they do and informs the constitutional analysis in several ways.

First, Rasul drew upon history, explaining that the common law writ remained available to individuals in territory under the control of the English crown. Viewed in that light, Guantánamo is an easy case given more than a century of exclusive U.S. jurisdiction and control. Rasul’s historical analysis is of constitutional salience because, as St. Cyr instructs, the Suspension Clause at least protects the common law writ as it existed in 1789. And, in 1789, the writ would have run to an enclave like Guantánamo.

Second, Rasul distinguished Johnson v. Eisentrager, 339 U.S. 763 (1950), in two ways. For purposes of the habeas statute, the Court concluded that under Braden v. 30th Judicial Circuit of Ky., 410 U.S. 484 (1973), a habeas petitioner does not need to be within the district court’s territorial jurisdiction (as he did at the time Eisentrager was decided). Hence, the Guantánamo detainees could invoke a district court’s jurisdiction under the plain terms of the habeas statute. The Court, however, also distinguished Eisentrager because, among other things, the petitioners there were conceded enemy aliens who had been tried and convicted by a military tribunal, not held indefinitely without trial. For this reason Eisentrager, as Steven Vladeck and others have pointed out, may be read as a decision on the merits. And, on the merits, Eisentrager is a very different case.

Finally, appellate review of a CSRT finding under last year’s Detainee Treatment Act (“DTA”) does not alleviate Suspension Clause concerns because it fails to provide a constitutionally adequate substitute for habeas under Swain v. Pressley, 430 U.S. 372 (1977). As St. Cyr makes clear, the DTA’s scope of review must encompass legal and constitutional claims, including the lawfulness of the administration’s designation of a prisoner as an “unlawful enemy combatant” and whether the CSRT violates due process. Yet, the statute, as written, arguably precludes that review, asking only whether “the use” of CSRT procedures is unlawful. But even if the DTA permitted that review, it would still fall short of the Suspension Clause’s requirement by foreclosing any meaningful examination of the factual basis for a prisoner’s detention.

As I previously argued for amici in the D.C. Circuit, habeas review traditionally guaranteed a searching inquiry into factual allegations in cases of executive detention without trial (as opposed to the narrower review in post-conviction cases, where the prisoner was afforded due process at trial). These common law protections were later codified in the federal habeas statute, 28 U.S.C. § 2241 et seq., a point noted by both Justice O’Connor in Hamdi v. Rumsfeld, 542 U.S. 507 (2004), and Judge Muskasey in Padilla ex rel. Newman v. Bush, 233 F. Supp. 2d 534 (S.D.N.Y. 2002), who saw the statute as providing a skeletal outline of due process independent from the Fifth Amendment. Indeed, it was when the administration recognized that the D.C. Circuit might actually force it defend its detentions in district court on habeas (including by entertaining allegations that evidence was obtained under duress), that it engineered passage of the DTA. Call it legislation as cover-up. In short, DTA review by the D.C. Circuit of a CSRT finding would not provide what common law habeas provided, but instead sanction indefinite detention without an opportunity to submit evidence or rebut the government’s allegations before a neutral decisionmaker. The CSRT’s basic inadequacy, coupled with the DTA’s narrow scope of review, does not satisfy the constitutional core of habeas.

A habeas case filed on the eve of the MCA’s passage challenging detentions at Bagram Air Base in Afghanistan will also raise issues important Suspension Clause issues. To be sure, Bagram does not possess the same century-long exclusive U.S. jurisdiction and control that makes Guantánamo unique. On the other hand, there is no alternative review scheme for detentions at Bagram since the DTA’s review mechanism applies only to detainees at Guantánamo. Thus, Bagram will force courts to confront the legal black hole they faced at Guantanamo before Rasul. It will also highlight the perverse incentives created by a jurisprudence that provides for review of detentions at Guantánamo but denies it at other off-shore prisons, allowing the administration to transfer prisoners to avoid the reach of the writ, exactly what habeas traditionally sought to prevent.

Tags: Justice, Liberty & National Security, Detention & Habeas Corpus

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The Runaway Executive: Trying to Escape Accountability Yet Again

*Cross-posted from ACSBlog

The Bush administration's blatant disregard for the legal process has become so routine that almost nothing it does is surprising at this point. Its most recent machination is to try to circumvent judicial review in the case of two Uighurs, an ethnic group from western China, detained without charge at Guantanamo. The men had been imprisoned for more than four years even though the government concedes they are "non-enemy combatants," or, in other words, innocent.

The case, Qassim v. Bush, was scheduled for oral argument in the U.S. Court of Appeals for the District of Columbia Circuit on Monday morning, May 8. However, late the previous Friday afternoon the government moved to dismiss the case as moot, asserting that the two detainees in Qassim, along with three other Uighurs, had been transferred to Albania for resettlement as refugees. The government claimed its extensive efforts to find a safe home for the Uighurs, who could not be returned to China for fear of torture, had finally "come to fruition."

It is difficult to believe the timing of the release was coincidental. It is far more likely that the government transferred the Uighurs to avoid an adverse ruling and to insulate its conduct from judicial scrutiny. A loss in Qassim would invalidate a key aspect of the government's detention regime at Guantanamo and reinforce the vitality of habeas corpus, which guarantees both the right to test the lawfulness of a prisoner's detention and an effective remedy where that detention is illegal. Further, the government feared that the court might order the Uighur's release in the United States where they could seek asylum, which, as Georgetown law professor David Luban observes, is the least we owe them after four-plus years' wrongful imprisonment at Guantanamo.

If the government succeeds in mooting the Qassim case, the district's court decision grudgingly upholding the Uighurs' continued detention would stand, and the administration would remain free to indefinitely detain the next group of non-enemy combatants. (There at least four more still in legal limbo). In short, the system of detention-without-remedy at Guant√°namo would remain intact.

Such last-minute ploys have become the modus operandi of an Executive branch bent on avoiding accountability for its detention and interrogation policy. In Hamdi v. Rumsfeld, for example, the Supreme Court rejected the government's contention that it could detain the petitioner, Yasser Hamdi, without due process, and ordered that he be given a fair hearing. Then, when confronted with its hearsay allegations being tested in federal court, the government agreed to release Hamdi even though it had previously said he was a dangerous terrorist whose detention was crucial to national security.

More recently, the government ducked Supreme Court review in the case of Jose Padilla, an American citizen imprisoned by the military for three-and-a-half years without charge. Just before its brief opposing Padilla's petition for certiorari was due, the government announced it had criminally charged Padilla and sought his transfer to civilian custody. Even though the Court ultimately declined to review the legality of Padilla's military detention, three Justices warned the government against any future manipulation of the legal process.

The Executive's attempt to avert a ruling in Qassim is thus part of an all-too-familiar pattern of circumventing the checks and balances at the heart of the Constitution. Sure, Congress still has the power to pass laws, but the President consistently says those laws do not bind him. As Charlie Savage of The Boston Globe recently reported, President Bush has issued signing statements claiming the authority to disobey more than 750 statutes since he took office, far more than any predecessor. When taken to court over its failure to follow the law, the administration simply moots the case to prevent the Judiciary from invalidating its action. This way, the President remains accountable to no one but himself.

The D.C. Circuit has granted a continuance of the oral argument in Qassim to give the Uighurs' counsel an opportunity to investigate the circumstances surrounding their clients' last-minute transfer to Albania. But even if the Uighurs' release in Albania is unconditional and consistent with U.S. obligations under international law (including the Convention Against Torture), there are good reasons to avoid dismissing the case on mootness grounds. Clearly, this is a situation capable of repetition, yet evading review. The government can continue to detain other concededly innocent detainees, forcing them to conduct protracted litigation before shipping them off to another country at the eleventh hour to avert a court order halting the illegal practice. If that is how the government is permitted to operate, the bedrock democratic principles of accountability and the rule of law will be empty slogans.

Tags: Justice, Liberty & National Security, Checks & Balances, Detention & Habeas Corpus

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