Balkinization  

Sunday, July 09, 2006

Open Letter in Response to Cass Sunstein on the NSA and FISA

Marty Lederman

Dear Cass:

Thank you so much for that gracious and thoughtful response to my provocation. I greatly appreciate it, and that fact that you've agreed to continue this dialogue here on the blog.

Obviously, I'm pleased that our disagreements are diminishing on the question of the legality of the NSA program. I'll have more to say shortly about Hamdan and the NSA matter (see also Jack's post, which strikes me as entirely correct); but in the meantime, here are some quick, off-the-cuff reactions to the points on which we appear to continue to have some possible differences:

1. I'm surprised that you are so dismissive of Congress's actual intent. Of course it isn't conclusive on questions of statutory construction. But just as surely, an interpretation that virtually no legislator intended, that comes as a shock even to the strongest congressional supporters of the NSA program, and that could not possibly have secured anywhere close to a majority had it actually been on the table in Congress, ought at least to be strongly disfavored, no? Purposivism, even in its mildest form, ain't dead yet, is it? (Witness Hamdan.)

2. You begin your analysis with an "if FISA did not exist" counterfactual. I agree that if FISA did not exist, the AUMF would likely authorize at least certain applications of the NSA program. We critics have long conceded that point. But, as you acknowledge, the counterfactual begs the only question that matters, namely, whether the President must comply with a pre-existing statute (FISA) directly on point. It's as if one started the discussion of Hamdan with the hypothetical question of whether the commissions would be lawful if Congress had never enacted the UCMJ and if the Senate had never ratified the Geneva Conventions. In fact, Justice Stevens (appropriately) begins his analysis (page 28) by stating that the Court "need not answer" that question, because there is a statutory framework in place that renders that question immaterial.

Similarly, if there were not a slew of statutes and treaties regulating interrogation techniques, perhaps the AUMF could be read to authorize the President to engage in techniques approaching torture. But what would that prove, in light of the fact that such statutes and treaties do exist?

There is a very elaborate statutory regime in place both for interrogations and for electronic surveillance -- and the statutory question is whether a single, general, nonspecific sentence in an AUMF displaces that entire corpus of preexisting law. (I do not, of course, mean to suggest that you ignore this point -- obviously, you don't. I'm simply not sure why you think that before Hamdan it "made sense" to begin the statutory analysis by imagining that FISA did not exist. It's like the old "Try not to picture an elephant sitting in the middle of the room with pink pajamas" challenge. Hamlet without the prince. Etc.)

3. Part of the NSA program probably wouldn't be ok, even in the absence of FISA, because of the Fourth Amendment. Here's what I've written elsewhere (with David Cole) on this point:
It appears that the NSA program collects surveillance that would not be approved under FISA if the administration were to seek authorization by a FISA Court under the statute. According to the Administration, under the program the NSA must only find "reasonable grounds to believe" that at least one party to the communication is a member or agent of al Qaeda or an "affiliated terrorist organization"—a standard that could permit wiretaps of the phones of U.S. persons in the United States who are not themselves al Qaeda agents. Thus, it appears that NSA does not require in every case that there be probable cause to believe that the target of the electronic surveillance is a foreign power or an agent of a foreign power. Under FISA as currently written, the FISA Court could not approve such surveillance, and the leading judicial precedent indicates that without judicial approval such surveillance of U.S. persons would likely violate the Fourth Amendment. See Zweibon v. Mitchell, 516 F.2d 594, 614 (D.C. Cir. 1975) (en banc) (plurality opinion) ("[W]e hold today... that a warrant must be obtained before a wiretap is installed on a domestic organization that is neither the agent of nor acting in collaboration with a foreign power, even if the surveillance is installed under presidential directive in the name of foreign intelligence gathering for protection of the national security."); id. at 689 (Wilkey, J., concurring in pertinent part) (agreeing with plurality that if an exemption from the Fourth Amendment's warrant requirement exists, "it exists only for a narrow category of wiretaps on foreign agents or collaborators with a foreign power").
4. The 15-day war provision in FISA, 50 U.S.C. 1811, is dispositive, even if one doesn't buy all the other pro-FISA arguments. That's why it's a centerpiece of the letters I've written to Congress with Geoff Stone and others. I genuinely don't see what the plausible response to it might be, other than returning to the claim that the AUMF implicitly supersedes even that provision.

You don't mention the "exclusive means" provision of FISA, 18 U.S.C. 2511(2)(f); but that provision, too, would have to have been impliedly repealed by the AUMF -- an argument that Hamdan pretty much eliminates (see the top of page 30 of the slip opinion).

5. Most importantly, I was very much aware of your Harvard and Supreme Court Review articles; and that's why I found your AUMF/NSA argument so surprising.

I don't agree with your strong reading of Chevron as applied to war. It's certainly undermined by Hamdan, in which the Court gave virtually no deference to the President's interpretations of ambiguous provisions -- even of treaty provisions!

Be that as it may, however, I was understandably sympathetic to the notion you expressed in those articles that where individual liberties are seriously implicated, the President can't act without clear congressional warrant. Alas, I'm afraid I can't quite agree with you that Hamdan speaks to this question -- particularly since the case only involved the rights of aliens detained at GTMO, whose constitutional protections are still uncertain (but cf. footnote 15 of Rasul). Because the case is about violations of statutory restrictions (Jackson's Category III), and because no claim of constitutional protections was in the mix, the Court had no occasion to suggest, or even speak to, any such clear-authorization requirement.

But if this is your view -- and in the New Republic piece you seem to embrace it strongly, even as applied to the rights of a detained alien in Hamdan -- then why doesn't that simply settle the FISA/NSA question? We might disagree on some matters, but I would have thought we would surely concur on at least this much:

(1) The the NSA program seriously implicates individual rights -- indeed, constitutional rights of citizens.

and

(2) However strongly one might read the AUMF, Congress has not clearly authorized the President to ignore the "exclusive means" for electronic surveillance that FISA prescribes.

On your own view of the "clear authority" doctrine -- and let's hope you're right that the Court will one day embrace it! -- why was the NSA program legal, even before Hamdan?

6. I agree that, as weak as DOJ's AUMF defense of the NSA program may be, "it's far better than some of the ludicrous passages in the 2002 memorandum by OLC on coercive interrogation." But talk about damning with faint praise! I don't even doubt that, as you suggest, DOJ crafted the AUMF argument in good faith. But you had previously stated that DOJ "probably has the better argument," and that if "FISA is interpreted as preventing the president from doing what he did here, then the president does have an argument that the FISA so interpreted is unconstitutional." As I understand it, these aren't your current views, especially in the wake of Hamdan. If so, I'm heartened to hear of it. And if not . . . well, then let's continue the debate!

7. One other thing, which is a bit ancillary to the specific NSA question: In your previous remarks, you stated that "the Department of Justice is the president's lawyer, and they have a duty, the lawyers there, to protect the president's Constitutional prerogatives." I concede that, at least on issues realting to national security and foreign affairs, it is not hard to find historical instances, in Democratic and Republican Administrations alike, where it appears this is how OLC understood its role.

But I think it's mistaken. OLC's task is to assist the President in fulfilling his constitutional obligation to faithfully execute the law. Of course, one might adopt the view, often attributed to Madison, that the law itself -- the Constitution -- contemplates that each of the political branches will (should?) interpret the law so as to best protect its own prerogatives. I don't entirely agree, for reasons I've begun to express elsewhere; but I concede that it is a rich, complex and unresolved question. For now, I simply don't want everyone to simply assume the truth of the oft-heard canard that OLC's proper role in construing the law is to press as hard as possible in the direction of presidential prerogatives.

Thanks again for engaging me on these issues. I look forward to further discussion.

Best,

Marty

Comments:

It's a shame James Madison disagrees with you and agrees with Cass. He laid it out in the Helvidius/Pacificus debate with Hamilton over the scope of Esecutive Power with respect to Treaties and Wars. Here's old JMAD:

The power to declare war is subject to similar reasoning. A declaration that there shall be war, is not an execution of laws. It does not suppose pre existing laws to be executed. It is not in any respect, an act merely executive. It is, on the contrary, one of the most deliberative acts that can be performed, and when performed, has the effect of REPEALING ALL THE LAWS operating in a state of peace, so far as they are inconsistent with a state of war and of enacting as a rule for the executive, a NEW CODE adapted to the relation between the society and its foreign enemy. In like manner a conclusion of peace annuls all the laws PECULIAR to a state of war, and revives the general laws incident to a state of peace.

It's pretty clear, the AUMF/Declaration of War, repealed all of the laws which operated in a state of peace(ie FISA, among others) and set in place a "New Code"(ie the NSA Program, among others) to adapt to the conflict with the foreign enemy.

The NSA program is a perfectly legal part of the "New Code" which was enacted by the AUMF/Declaration of War.

All of this would be much clearer if Congress had explicitly declared war on Al Qaeda, but with the War Powers Act and recent history, it's afe to say that Congress will never again declare war on anyone and that AUMFs are the functional equivalent of declarations of war for Constitutional purposes.

It's all so simple, Madison laid it all out 200 yrs ago. Now, are you going to call "The Father of the Constitution" a radical right wing fascist like you do Bush ?
 

nobody around this blog is calling mr. bush a facist, so let's cut out the nonsense.

selective quotes always produces interesting results. i find it interesting as well, that ms. weddington believes that a debate outside of congress has some sort of stare decisis on this issue. yes, madison was a founding father, but then again, so was hamilton, and this being a debate, there had to have been another side. i don't have the time or inclination to look up what hamilton's position in response to madison's was. i did have the time and inclination, however, to look up the supreme court's determination on this issue, which is in the steel seizure case (youngstown sheet & tube co., et. al. v. sawyer, 343 us 579), and noted that all the arguments over article II powers that bush claims allows him to supercede or suspend all laws passed by congress were rejected by the supreme court over fifty years ago. it is worth noting the sharpness of the rebuke in the ultimate paragraph of justice black's decision:

"The Founders of this Nation entrusted the lawmaking power to the Congress alone in both good and bad times. It would do no good to recall the historical events, the fears of power and the hopes for freedeom that lay behind their choice. Such a review would but confirm our holding that this seizure order cannot stand".

i submit that the aumf is not a declaration of war. if congress wanted to actually declare war, it easily could have done so. there is a constitutional mechanism for doing so. please don't try to claim that the aumf is such a declaration. even if it was, the steel seizure case clearly mandates that the president's powers are fixed by the constitution (even if some founding fathers disagreed, but isn't that democracy?), and that he has no authority under article II to usurp the powers of congress, even in wartime.
 

Dear Marty: from a non legal mind thank you for typing your post slowly ...
 

First of all, I'm not suggesting Madison is the be all and end all. However, the fact that he said that does show that the WH's view does have support and isn't some totally made up fantasy. As for Madison vs Hugo Black, with all due respect, I'll take Jimmy any day of the week.

As for the AUMF vs Declaration of War, I acknowledged that this would all be a lot easier if Congress has declared war a la WW2. However, with the War Powers Act and the way things are, I think its obvious that ongress will never again delcare war on anyone as it did in WW2 so for all intents and purposes, the AUMF is the same thing as a declaration of war.

Are you saying that if Congress had declared war explicitly taht the NSA program would then be legal?
 

no, i'm not saying that the nsa program would be legal if congress had declared war. i am saying that nobody, and i mean nobody is above the law, including the president, as was stated by the united states supreme court, as was stated by the united states constitution.

btw, i wonder if you would be taking the same position if the president putting forward these programs was bill clinton...
 

I would be.

What part if "Repealing all the laws operating in a state of peace, so far as they are incocnsistent with a state of war and of enacting as a rule for the executive, a new code adapted to the relation between the society and its foreign enemy" don't you understand? Madison could not have been any clearer.

I;m not saying I agree with him 199% or not, but the fact is that Madison is worthy of respect, certainly much more respect in my book than Justice Stevens and the other liberals on the bench.

The same liberals that have decreed that the Constituution also guarantees the right to partial birth abortion, gay sex, and Geneva rights for terrorists and countless other things while it forbids the death penalty, term limits and single sex military academies.

Stevens pronouncements on the Constiution are worthless to me.

My main point is that the WH does have support for its position and this idea that they are radically abusing the Constitution doesn't even pass the smell test.

John Paul Stevens and his liberal accomplices threw the Constitution in the trash years ago and haven't paid much attention to it sense.
 

Sarah Weddington is much enamoured with that Madison quote, so muhc so as to repeat it for the hard of hearing. But, as with all things, if you search hard enough you wil find some quote somewhere that can be twisted to support your views. One thing to note here, though, is that the Constitution itself was hardly unaware of the distinctions between peace and war, placidity and peril, and noted in particular what could be done in wartime (see Article I, Section 9). Sarah ignores that, and seems to insist that during war, all bets are off, and the whole shebang is up for grabs. This flies in the face of both history and common sense interpretation of the Constitution under the most accepted ruled of interpretation.

Surely, if the rather drastic changes in the form of gummint in times of war that Sarah is expounding here if fact were what was intended by the founders, she'd have more than one single (and unsourced) quote, and plenty of history and legal precedent to back that up. She doesn't. She's just throwing out rather old fish so see who will refrain from holding their noses ... but that is not me.

Cheers,
 

Sarah Wddington said:

Stevens pronouncements on the Constiution are worthless to me.

If you ask Justice Stevens, you shouldn't be surprised if he says the same about you, given your attitude. He's a Supreme Court Justice, though, and you're not.

Cheers,
 

Gee,
I don't have history on my side?

What are you smoking?

Read up on the Civil War, WW1, WW2 etc... War does change the rules.

During war, the govt can make me a virtual slave and force me at punishment of imprisonment to go to Iraq and die. You don't think that changes the rules?

During war the SC declared thta plenty of things unthinkable in peace time, ie camps/curfews/etc,,, are legal That didn't change the rules?

During war, the govt can impress property, establish martial law, suspend habeas corpus, all sorts of things. That doesn't change the rules?

Give me a break

I have plenty of other quotes besides Madison's. I won't repet them all, but as the "Father" of the Constitution, one quote from Madison is worth 100 by anyone else. Read Curtiss-Wright, Read Korematsu/Hirabyashi, read the dissents in Hamdan and Rasul. Read the opinions mentioned in OLC's brief on the TSP. There's plenty of quotes and opinions to back up the WH.

And if they get on emore conservative on the Court, the SCOTUS will back them up as well.

As for Stevens, I could care less what he thinks of me. He may be a Supreme Court Justice, but I haven't aligned myself with Al Qaeda and allowed the slaughter of 40,000,000 babies to continue. I hope he sleeps well at night down in the Keys.
 

The AMUF does not equal a Declaration of War. If Congress wanted to Declare War and give the President those powers they would have done so. Since they did not, he doesn't get them.
 

Sarah, those examples you gave of things that the "government" can do in wartime are primarily things that Congress does, like institute the draft, etc.

Or, they are actions done in the absence of Congressional prohibition, like interning the Japanese.

Your position, if it were correct, would mean that tomorrow, the President could order the troops to bust into your house, grab you, and hang you in a public square, simply if he claims that such actions are necessary for the public defense. Are you sure you want to advocate for that position? (If you disagree, I'd appreciate your explaining what prevents the President from doing that after passage of the AUMF.)

At any rate, I think your argument was rejected pretty squarely last year in the Hamdi and Padilla cases. Didn't eight members of the Supreme Court reject the argument that a declaration of war allows the President to disregard statutes? And even Justice Thomas did not argue that the AUMF effectively repealed all pre-existing statutes.
 

Sarah Weddington sez:

Gee, I don't have history on my side?

I think it's the facts that you are missing.

What are you smoking?

Sorry, between you and me, I'm the sane one here. Did you think that was an argument?

Read up on the Civil War, WW1, WW2 etc... War does change the rules.

Well, lessee:

During war, the govt can make me a virtual slave and force me at punishment of imprisonment to go to Iraq and die. You don't think that changes the rules?

Ummm, sorry, we had a peace-time draft (or at least SSS) too. Has nothing to do with "war" outside fo the fact that the cannon fodder is run through at a greater pace under such circumstances.

During war the SC declared thta plenty of things unthinkable in peace time, ie camps/curfews/etc,,, are legal That didn't change the rules?

Huh? If you're talking Korematsu, that ruling is seen by pretty much every rational person nowadays to have been a big mistake, and a sad blot on our history.

During war, the govt can impress property, establish martial law, suspend habeas corpus, all sorts of things. That doesn't change the rules?

As I pointed out to you, those powers are limited an enumerated by the Constitution. As for "impress property", you might look at Youngstown. Yes, Congress can pass laws (including a draft) to deal with the exigencies of war, but they have no greater power during times of war than they did in peace ... except for the limited powers enumerated in the Constitution (and the oft-forgotten Third Amendment), which includes the suspension of habeas, FWIW.

But your claim is there is a "repealing [of] all the laws operating in peace". This is, quite simply put, outright wrong.

Give me a break

Why? Because you're an eedjit? That may fly, but if it's simply a matter of being lazy and uneducated about what the Constitution says, I don't think your errors deserve any slack.

I have plenty of other quotes besides Madison's. I won't repet them all, ...

No, you'll keep repeating the one quote you've got (and that you like). Funny, though, I don't see any cite for it, though. Anything like David Barton's manufactured quotes?

... but as the "Father" of the Constitution, one quote from Madison is worth 100 by anyone else....

Sorry to disabuse you of your fantasies, but the words of the Constitution itself are more authoritative than any quotes attributed to individual authors (or signers). And, as I pointed out above, the Constitution itself says what can and cannot be done in wartime. This is just elementary Constitutional interpretation (and common sense, I might add).

... Read Curtiss-Wright,...

Ummm, what's your point?

... Read Korematsu/Hirabyashi, ...

I have. As I said, most people think that Korematsu was a mistake.

... read the dissents in Hamdan and Rasul....

Why? Do you think that dissents are good law?

... Read the opinions mentioned in OLC's brief on the TSP....

Feel free to cite any you think are apposite. You know, expecting me to do your thinking and arguing for you is likely to lead to a result that you won't be happy with. Make you case. Back it up.

... There's plenty of quotes and opinions to back up the WH.

And there's plenty on the opposite side. The opposite side in Hamdan had more Supes signing on.

And if they get on emore conservative on the Court, the SCOTUS will back them up as well.

And for now, you're just spouting your own uninformed opinion, not the law of the land.

As for Stevens, I could care less what he thinks of me. He may be a Supreme Court Justice,...

That does count for something in a court of law.

... but I haven't aligned myself with Al Qaeda and allowed the slaughter of 40,000,000 babies to continue....

OIC. My. One-trick-pony, eh?

... I hope he sleeps well at night down in the Keys.

Oh, I'm sure you do. You're that honest, I can tell.

Cheers,
 

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Effects 825 Hoodia Side Effects 826 Hoodia Side Effects 827 Hoodia Side Effects 828 Hoodia Side Effects 829 Hoodia Side Effects 830 Hoodia Side Effects 831 Hoodia Side Effects 832 Hoodia Side Effects 833 Hoodia Side Effects 834 Hoodia Side Effects 835 Hoodia Side Effects 836 Hoodia Side Effects 837 Hoodia Side Effects 838 Hoodia Side Effects 839 Hoodia Side Effects 840 Hoodia Side Effects 841 Hoodia Side Effects 842 Hoodia Side Effects 843 Hoodia Side Effects 844 Hoodia Side Effects 845 Hoodia Side Effects 846 Hoodia Side Effects 847 Hoodia Side Effects 848 Hoodia Side Effects 849 Hoodia Side Effects 850 Hoodia Side Effects 851 Hoodia Side Effects 852 Hoodia Side Effects 853 Hoodia Side Effects 854 Hoodia Side Effects 855 Hoodia Side Effects 856 Hoodia Side Effects 857 Hoodia Side Effects 858 Hoodia Side Effects 859 Hoodia Side Effects 860 Hoodia Side Effects 861 Hoodia Side Effects 862 Hoodia Side Effects 863 Hoodia Side Effects 864 Hoodia Side Effects 865 Hoodia Side Effects 866 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Effects 908 Hoodia Side Effects 909 Hoodia Side Effects 910 Hoodia Side Effects 911 Hoodia Side Effects 912 Hoodia Side Effects 913 Hoodia Side Effects 914 Hoodia Side Effects 915 Hoodia Side Effects 916 Hoodia Side Effects 917 Hoodia Side Effects 918 Hoodia Side Effects 919 Hoodia Side Effects 920 Hoodia Side Effects 921 Hoodia Side Effects 922 Hoodia Side Effects 923 Hoodia Side Effects 924 Hoodia Side Effects 925 Hoodia Side Effects 926 Hoodia Side Effects 927 Hoodia Side Effects 928 Hoodia Side Effects 929
 

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