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Liberty & National Security

Why Virgil Goode is So Wholly Wrong

*Cross-posted from The Huffington Post

As Cenk Uygur has explained, Virgil Goode's slur is a naked attempt to link terrorism, immigration, and Islam in a way that panders to the ugliest kind of nativism. It's worth stepping back too to look at why Goode is so wholly wrong.

For Goode is far wide of the mark when he suggests that Muslims in the States are all immigrants. Indeed, the history of Islam in America, as documented most recently by Genieve Abdo shows how Muslims, have been part of the American story from the very beginning, albeit sometime at the margins.

Muslims have been embroiled in the task of becoming Americans from the very beginning of the nation. I'm certain that Goode is not alone in forgetting that many Muslims were living in the United States before there even was a United States--as slaves. Islam was common in the West Africa (many Muslims were merchants in the region) when that part of the world was a hunting ground for slaves. Records from the Revolutionary era list slave names and reveal many Muslims among those who made the Middle Passage. And Islam was not snuffed out by the horrors of slavery. As late as 1837, a slave narrative by one Charles Ball documents slaves engaged in the five daily prayers that Muslims do.

A second wave of Muslim immigrants came as part of the effort to conquer the American West at the end of the nineteenth century. The first mosque in the United States was built, according to Abdo, in Ross, North Dakota. A commemorative plaque in Quartzsite, Arizona celebrates a Syrian immigrant known as "Hi Jolly" (in fact, Hajji Ali), as "a faithful aid to the U.S. government."

Today, Hajji Ali finds his latter-day counterpart in the FBI agent Ali Soufan: As Lawrence Wright has movingly recounted, Soufan came within inches of unraveling the 9/11 plot, failing largely due to the CIA's failure to share its data hoard. When Goode attacks Muslims as incapable of being Americans, he spits not only on the grave of men such as Hajji Ali who have (quite literally) built America, he also tars the dignity and loyalty of proud government servants such as Soufan.

To say that Muslims or Islam is somehow "alien" to America is thus at least ironic--and at worst the evidence of an ugly and stupid prejudice.

Today, an accurate count of Muslims in the U.S. is hard to find. Estimates ranging from 1.1 million to 7 million. About a third of American Muslims were born in the United States, and many others are non-citizens. Large Muslim communities now live in New York, Chicago, Detroit, and Dallas/Fort Worth-Houston. They include Sunni and Shia; they encompass the covert, the pious and the lapsed. There are no easy stereotypes about the manifold ways of being a Muslim American in 2007.

Indeed, Islamic doctrines more broadly are also far more complex than first appears. As Cenk explained, there is no doubt that there are some pathological ideologies that claim to be Islamic--and these must be marginalized and wiped out. But it should not need repeating that the overwhelming majority of Muslims have no interest in or appetite for political violence. The sheer number of Muslims in Europe and the United States, set against the single-digit infrequency of ideological violence, ought to give the lie to any such claim.

One hundred and fifty years ago, Virgil Goode might have made the same speech - except where he used "Muslim" today, he would have been using "Catholic" one hundred and fifty years ago. The now-defunct "Know Nothing" party panders to fears about Irish and Italian immigration. It invoked the specter of Northeastern port cities being overrun by the papist lower classes. Know Nothing politicians accused Catholics of "ultramontainism," that is owed a first and foremost allegiance to the Vatican, and thus being incapable of being a loyal American.

Just as the Know-Nothings were proved wrong--and have largely been left in history's dustbin--so too will Virgil Goode's smear one day remain only as evidence that America can overcome its darker impulses. Muslims, like any other community of faith that is rooted here, and that has links overseas, have been and can be a part of the diverse and shifting fabric that is today and will be tomorrow America.

Aziz Huq: "Why Virgil Goode is So Wholly Wrong" (pdf) 

Tags: Justice, Liberty & National Security, Domestic Counterterrorism

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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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Disposable Pawns in a Game of Diplomatic Chess

*Cross-posted from The Huffington Post

In a federal court of appeals in Washington, DC today, a case has been filed that casts troubling light on the apparent willingness of the United States government to detain innocent men as "enemy combatants" in order to secure international support for its 2003 invasion of Iraq.

Here, in brief, are the facts described in the filing.

In 1949, Maoist China seized a new far western province known to many of its inhabitants as East Turkistan. Calling the new province "Xingjian," the Chinese ruthlessly suppressed political and religious diversity. Thousands of ethnic Uighers, who are Muslim by affiliation, fled the province.

Among those who sought new lives free of Communist oppression were twenty-three Uighers, who ended up in northern Afghanistan--long an entrepot for Afghans, Turkic, and Chinese peoples. They lived in a village near the eastern town of Jalalabad, doing odd construction and manual labor. They never fought with either al Qaeda or the Taliban. After their village was bombed in the American invasion of October 2001, they fled to Pakistan.

In December 2001, the Uighers were seized by Pakistani forces and handed over to America for $5000 ransoms. It is a matter of public record that the Pentagon, on the advice of Justice Department lawyers, did not screen its detainees to determine if it was properly holding them: It simply assumed everyone seized was a terrorist.

Grabbed by bounty hunters hungry for money, far from any battlefield, the Uighers were nevertheless taken to Guantánamo. They were labeled the worst of the worst and confined in cages. In a foreign land, they were stranded, cut off from their culture, their homes, their friends, their families.

After three years' detention without any process whatsoever, the Uighers were given the first chance to present their case to a "Combatant Status Review Tribunal," or CSRT. The military explicitly told detainees that the CSRTs were not "habeas review"--that is, the traditional judicial text for unlawful detentions. It is telling that CSRTs were conducted at a rate of 50 per week. The Uighers had no lawyer. They had no way of getting evidence. They were not permitted to see the evidence against them.

A CSRT, indeed, is a simple affair. The officer says, "You're in al Qaeda." The detainee says, " No, I'm not, and if you allow me to present evidence, I can prove it." The officer refuses, stamps the file "enemy combatant"--and we're done for the day.

Much of this is known. What was not known until now is why this decision was made. In August 2002, as Iraq war drums was neared their zenith, Deputy Secretary of State Richard Armitage traveled to China to talk about the war that the United States had already decided to launch in Iraq.

But, for the Chinese, the Uighers were an issue. They demanded that the United States recognize the Uighers as a terrorists, and designate Uigher political dissidents as members of a terrorist group. Armitage complied.

It appears that the August 2002 agreement reached with China was even more detailed. In September 2002, mere weeks after the Armitage visit, the filing explains, Chinese interrogators visited Guantánamo to question the Uighers--and used with American authorization coercive techniques such as environmental manipulation, stress positions, and stress deprivations.

Let me reiterate what the Uighers' filing credibly asserts: At a U.S. military facility, the United States permitted Chinese intelligence agents to torture detainees as quid pro quo for Chinese support for the Iraq War.

Of course, by time the war began, Chinese support within the U.N. was, shall we say, less than imperative. In April 2003, the Uighers were told, in the words of one interrogator "You are innocent. I am closing the file on you." The United States began looking for a country that would take the Uighers (who would be tortured if sent to China). Three years later, several are still there.

The question today is whether the United States will continue to keep innocent men in cages for years on end. It is a question of whether to treat human beings as disposable pawns in a grand game of diplomatic chess. A question of whether our principled belief in human dignity must yield before the expediencies of illegal and unwise warmongering.

Last week, the Justice Department issued an apology to Brandon Mayfield, an Oregon lawyer who had been wrongly detained as a "material witness" and criminal suspects in the March 2004 Madrid bombing. Mayfield, another innocent swept up in reckless and feckless counter-terrorism operations, could have sued--and would doubtless have secured a considerable (and embarrassing) judgment.

The Uighers, however, cannot invoke the shadow of money damages: Recent legislation cuts off all money damages claims based on abuse and mistreatment in global money damages claims. Unlike Mayfield, they must ask the United States to do the right thing for its own sake.

Apparently, that's not enough for this Administration.

Indeed, the Uighers must cling to sanity and life against dire odds. Their presence in U.S. hands is a continuing shame. A persistent scar on America's reputation for honesty and decency.

In September, Congress passed the Military Commission Act, which purports to limit the ability of federal courts to scrutinize the facts surrounding certain detention decisions. The case of the Uighers shows why the government wants to limit scrutiny.

When the Democrats took control of the House and Senate, they promised accountability. For many Americans and for many citizens of other nations, it is too late. But for some of the victims of collateral damage from the Iraq war, the clock has not struck twelve. We still can do some modicum of justice, save some cinder of face.

We should do so without delay.

Aziz Huq: "Disposable Pawns in a Game of Diplomatic Chess" (pdf) 

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

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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.

Aziz Huq: "A Symbol of 'Extraordinary Rendition' Returns to the U.S." (pdf) 

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

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Who Watches the Home Front?

*Cross-posted from The Huffington Post

Oversight is the rallying cry of the new Democrat Class of '06. But there's a danger that the policy area most obviously in need of real accountability - our domestic national security agenda - will get short shrift in the rush to address the Iraq debacle.

Legislators moved quickly on Iraq. Legislation to revive the Special Inspector General for Iraq Reconstruction has already been flagged for the lame-duck Congress. Inquiry into the myriad iniquities that make out America's Iraq policy is a no-brainer for the new Congress. And Rumsfeld's "resignation" is a sure sign that the Administration is battoning down the hatches in preparation for some heavy weather.

While Iraq is of unquestionable importance, there's also a pressing need for oversight on domestic security issues: How are our intelligence agencies and military behaving closer to home? So far, too little attention has been paid to this question.

For at least the past three years, the American public has been hearing stories of torture, the "extraordinary rendition" of suspects to torture, disappearance, detention, and warrantless surveillance. But to date, Congress has conducted no substantial inquiry into the full facts around any of these policy areas. In consequence, the executive branch has been able to control the narrative.

For example, with respect to torture, a plethora of internal executive branch investigations have produced fragmentary, and likely misleading, reports on the connection between political appointees in Washington, who developed legal justifications for torture, and interrogators out in the field, who put those justifications into practice. There is a need for sustained oversight that goes beyond the current quagmire in Iraq. We need to know not only how we have gone wrong - and violated core individual rights - of innocent men and women over the past five years, but also how we can avoid those same mistakes in the future.

This oversight is especially important because the policies at issue - torture, "extraordinary rendition," wiretapping - were fashioned without congressional input or oversight: So they will likely continue unabated, with the attendant harms this causes, until Congress steps in.

At a minimum, we need serious and substantial inquiries soon into the following topics:

  • The activities of all military intelligence gathering agencies in the United States. It's not just the NSA we need to worry about. Several months ago, Walter Pincus of the Washington Post wrote a series of superlative articles about a military agency called CIFA, or the "Counter-Intelligence Field Activities." This agency had been collecting reams of data on civilians in the United States, including anti-war protesters. There has never been a full accounting of CIFA's role or responsibilities - let alone the kind of synoptic overview of what military intelligence is doing in the United States, which the American public are long overdue.
  • The actual interrogation policies of the CIA, and any military intelligence agencies that are engaged in detention and interrogation policies. Startling, the White House continues to resist disclosure of even the most generic documents on this matter, documents whose disclosure poses no risk of compromising national security. For example, there is an August 2002 Justice Department memo, a sibling to the infamous "torture memo" of the Office of Legal Counsel, which analysis a series of specific interrogation tactics (Waterboarding? Cold cell? "long time standing"? Is this where the Vice President gets his impression that waterboarding is just dandy--and legal?). Did the Justice Department find these tactics all legal? Ethical? Did it even ask the ethical question? We don't know until we see the memo and see how it was operationalized.
  • Our relations with foreign intelligence agencies: The Who's, the What's, and the How's. It is by now clear that the United States maintains standing relationships with the world's most brutal and anti-democratic intelligence agencies, including Syria's, Egypt's, and Jordan's. There has been virtually no disclosure - and scant public debate - about what we are doing supporting the least democratic elements in countries we are supposed to be supporting democracy in.

These are the tips of the proverbial iceberg. Finding out how deep the iceberg runs is the task of oversight. It's about time we started getting some answers.

Aziz Huq: "Who Watches the Home Front?" (pdf) 

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

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Hurry Up and Wait: The Torture Legislation and the November ‘06 Elections

*Cross-posted from The Huffington Post

Two weeks ago, the White House led a chorus baying for the blood of anyone who stood in the way of the President's Military Commission Act stood in the way of defending America. After five years' inaction on detainees and interrogation issues, the White House discovered a need for speedy action. But a week after the House and Senate voted on the bill, the enrolled bill is still sitting on President Bush's desk... No law has changed--yet. As thousands hit the streets to protest Congress's endorsement of cruel and inhumane interrogation techniques, and detention without end, it's worth asking: Why the delay? What does it tell us about the legislation, or the upcoming election campaign?

First and foremost, the delay illustrates a simple fact: There was no pressing need to act. The only pressing need driving enactment of the Military Commissions Act--with its frontal assault on rules against torture, indefinite detention, and fair trials--was the prospect of November elections.

The Administration pointed to two pressing needs in its campaign for the legislation: First, it wanted President Bush's "program" of coercive interrogations in secret CIA prisons around the world to go forward. Second, it wanted trials by new military commissions for those held at the Guantánamo Bay to begin again.

But were either of these needs in fact pressing? The Administration's own behavior suggests not.

A senior intelligence official quoted in the Washington Post explained that "there is no one in CIA custody today" who could be subject to the coercive techniques allowed by the Act. Setting aside the question whether torture works as a means of securing accurate intelligence--it doesn't--it thus appears that the CIA is not now holding anyone who might have information to prevent an incipient attack. Like many previous announcement about incipient terrorist threats, the timing of the White House's warnings had more to do with politics than threat predication.

The idea that there's a pressing need to begin military commissions is even more transparently false. According to Defense Department spokesman Bryan Whitman, no trials are imminent. It will take at least until next year to rewrite rules, assign judges, and make the necessary arrangements for trials.

This legislation, in other words, had nothing to do with an immediate need. Instead, we now have repeated confirmation that the Administration, when confronted by real evidence of threats to American civilians, has simply failed to act. From the aching minutes that President Bush first took to register and respond to the news of the 9/11 attacks to the painful and disastrously inadequate response to Katrina, this Administration's record speaks for itself.

Recent revelations confirm this. Bob Woodward's new book State of Denial thus exposed the fact that CIA chief George Tenet and Cofer Black (who faced off against bin Laden in Sudan) warned Condoleezza Rice in the starkest terms of the looming assault--in a meeting the Secretary of State cannot even recall. Woodward's revelation echoes Ron Suskind's account in The One-Percent Solution of the CIA's desperate effort to warn President Bush in August 2001 of the impending crisis--only to be completely blown off by the vacationing Chief Executive.

Repeatedly, we learn that our leaders failed to respond to the threats. Repeatedly, these same leaders are all too ready to conjure those same threats for narrow, partisan purposes untethered from the true security needs of the nation.

This year's election season will bring a slew of claims and counter-claims about who is "toughest" on national security. But there's little point in hanging tough if you are facing the wrong way. The Military Commissions Act that sits on President Bush's desk is the worst sort of political showmanship: For reasons I have explained earlier, it will do little to keep us safer in the face of any imminent threat. It is rather a naked attempt to distract us from the gamut of real problems that today go unaddressed by haphazard, heavy-handed, and ineffectual executive branch approaches to national security.

 Aziz Huq: "Hurry Up and Wait: The Torture Legislation and the November Elections" (pdf)

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

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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.

Jonathan Hafetz: "Suspending Habeas Corpus at Guantanamo and Beyond" (pdf) 

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

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Junking Checks and Balances?

*Cross-posted from The Huffington Post

"Checks and balances" has a nice ring. But it's a currency that doesn't go a long way in Washington today.

The Military Commissions Act of 2006, of MCA, passed by the House and Senate and likely to be signed by the President tomorrow is a wholesale assault on the idea of a limited government under law. It will be taken by the Bush Administration as a blank check to torture, to detain indefinitely without just cause, and to trample the values that win America respect in the world. From tomorrow, counter-terrorism is the "land of do as you please" for the President and the wise men of the Defense Department--those savants who brought you Iraq, the gift that keeps on giving (at least if you're a jihadist).

The MCA comprehensively assaults two ideas: The idea of checking executive power by laws. And the idea of a separate branch of government ensuring those limits are respected. These are the basic tools of accountability. The MCA frontally attacks both of these--although only time will tell whether it succeeds.

How does the Military Commissions Act assail checks and balances? Consider the key issues of detention and torture.

The MCA says nothing explicit about the detention power. Indeed, I would argue that nothing in the legislation ought to be read to imply a detention power. Of course, that's not what David Addington and his colleague Alberto Gonzales will tell us. Rather, they will contend--publicly or not, it's hard to predict--that the MCA allows the executive branch power to detain literally anyone it wants provided it complies with a token gesture at procedure.

Here's how the Addington play for detention power will work. The opening definition of the Act describes elaborately what an "unlawful enemy combatant" is. Why? The term is a neologism. The laws of war do not use or define this term. Indeed, it is a mutation of a phrase used in a subordinate clause of a 1942 Supreme Court opinion. Nothing else in the Act directly turns on this definition--although only an "alien unlawful enemy combatant" can be subject to trial by military commission. So why bother with the elaborate definition? And why extend the definition to U.S. citizens as well as non-citizens?

Back in 2004, the Supreme Court, in the now well-known Hamdi v. Rumsfeld decision, stated that an "enemy combatant" captured in hostilities could be held for the duration of those hostilities. The Court made very clear it was talking about only the limited context of the ground war in Afghanistan, not some amorphous and unending "war on terror." But Addington et al. will, however, take Hamdi's sanction of detention--and extend it far, far beyond Hamdi. It will be a detention power that applies anywhere and anytime.

There are two ways in which you--citizen or non-citizen, resident of Topeka or Timbuktu--can become an "unlawful enemy combatant."

The first way is if you engage "in hostilities" or "purposefully and materially support" hostilities. This sounds reasonable enough until you realize that no-one has the slightest clue what it means to "purposefully and materially support" hostilities. Do you need to intend to aid the hostilities? Or is it enough to intend to give the support? Would purposely giving to a charity that then gave money to Hamas count, even if you knew nothing about the Hamas? What about writing an editorial that gave "aid and comfort" to the enemy--say, by criticizing the Administration's Iraq policy?

The second way is--if it's even possible--more dangerous: You are designated an enemy combatant by a Combatant Status Review Tribunal--the Potemkin proceedings jerry-rigged at Guantánamo--or you are designated by "another competent tribunal" created by the Defense Secretary.

It's the latter that catches in the throat, because the MCA does not define what Rumsfeld's "competent tribunal" must look like. Rummy himself with the always-fair-and-impartial Addington? Five Syrian torturers (like the ones to whom the U.S. sent the hapless Canadian Maher Arar)? A bunch of guys who flip coins for your liberty? Sure, why not? The MCA doesn't stop the executive from using any of these, provided Rumsfeld gave them power and hence made them "competent."

At least for non-citizens, moreover, that would be that: For the first time in U.S. history, an Act of Congress singles out a group of persons--non-citizens--and deprives them of any right to challenge their detention wherever they are picked up. No non-citizen would, the MCA seems to say, be able to challenge this detention. And while citizens are certainly entitled to a hearing, the Government will fight tooth and nail to make sure this hearing doesn't allow any effective inquiry into the facts on which a detention is based. So no judicial review--and no accountability.

The same dynamic is at play in the anti-torture rules. The MCA alters a criminal statute called the War Crimes Act, which imposed criminal sanctions for certain violations of the laws of war.

Until recently, the United States could proudly point to a long history of supporting a universal ban on torture, and to a strong record in ensuring that those who in fact tortured did not escape accountability. No longer. Now a gamut of horrendous kinds of treatment will be non-criminal--and, the Bush Administration will argue, within the discretion of the President.

Start with the substantive anti-torture rules themselves (which cover both torture and the lesser "cruel and inhuman" treatment). The MCA contains an incredibly complex and convoluted set of definitions. Despite all the cant about clarity, the rules no longer in plain English--as they were in Common Article 3 of the Geneva Conventions --and they are so full of holes they might have been tortured themselves.

Here are three examples of the duplicitous ambiguity of the MCA when it comes to torture and abuse.

First, "cruel and inhuman" treatment is defined as acts that cause "severe or serious" pain. We know "severe" is worse than "serious" because "severe" is used to define torture (yes, we'll get there in a moment). But then "serious pain" is defined as "bodily injury" that causes "extreme physical pain." So "serious" pain is only "extreme" pain? Isn't extreme worse than serious? It would seem so--but the MCA is deliberately confusing and circular.

And why the reference to bodily injury? Does that mean that hypothermia and long-time standing and those other wretched "enhanced" techniques more fitting for Stalin's gulags than American facilities are not criminal? Well, yes, I reckon it does.

Second, in another convoluted section, "serious mental pain" is defined in terms of "non-transitory" harms. Thus, if a CIA agent threatens to kill a detainee, or to rape his spouse and his children--all long-recognized as forms of torture--that's not torture; it's not even the lesser "cruel and inhuman" treatment.

Finally, the torture statute itself. Almost unnoticed, the Bush Administration has gutted the no-torture rule. It has added the requirement that a person "specifically" intend to cause the pain that amounts to torture. This technical change--foreshadowed in the August 2002 OLC memo--has tremendous implications. It means that any government agent who says his goal was to get information, and not to cause pain, hasn't tortured no matter how bad the things he does. If the person water-boards or knee-caps a person, or buries them alive, if it's to get information--well, that's just dandy.

Once again, it's not just the substantive rules that have been assailed: It's also the mechanisms to ensure the rules are followed. Under the MCA, there is no accountability for torture. The MCA cuts off courts' power to hear claims of torture by aliens held as "unlawful enemy combatants." And it vests the President with power to interpret the relevant laws of war. So if he says that "cold cell" and sexual abuse are not "cruel and inhumane," that's the end of the matter.

There are two reasons for hope. First, any reading of the Act that reaches an untrammeled detention power may be unconstitutional. The Supreme Court in the 2004 case of Rasul v. Bush--in what one day will be called "famous footnote 15"--strongly hinted that even non-citizens captured overseas have Due Process rights. Combined with another clause of the Constitution called the Suspension Clause, this means the unchecked detention power and the jurisdiction-strip are likely unconstitutional.

Second, even if the War Crimes Act has been amended, the Due Process Clause also ought still to protect detainees held overseas: Torture is un-American. It's also unconstitutional--and that doesn't change depending on where it's done. Moreover, the law of war, embodied in the Geneva Conventions, is clear: There is no "specific intent" requirement for torture. Countries--whether it's the United States or North Korea--cannot unilaterally define down the rules against torture.

"Unchecked and unbalanced" government--I argue at length in a forthcoming book--is antithetical to American government. The MCA is also anathema to our best traditions. We must hope it is our traditions that win, and not the selfish partisan posturing that animated this week's votes.

 Aziz Huq: "Junking Checks and Balances?" (pdf)

Tags: Justice, Liberty & National Security, Checks & Balances

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