Wednesday, March 28, 2007
A [Guilty] Plea for Freedom?
David Glazier, Associate Professor of Law, Loyola Law School Los Angeles
If Hicks is regarded as an enemy soldier, then it is true that providing support to a terrorist organization is not a recognized violation of the laws of war for which he can be charged. However, under this classification it is impossible to dispute that he is a prisoner of war who under international law can be held in military custody until the end of the hostilities. This invalidates his MCA conviction, but validates his continued Guantanamo imprisonment.
However, he asserts that he was a civilian associate of al Qaeda leaders. If he was a civilian, but one who took military training, deployed in combat locations, and planned combat activities, then he can be charged with civilian crimes befitting his status as a civilian and unprivileged belligerent.
The problem here is getting specific evidence. A soldier can be captured anywhere and held simply because he is a soldier. A civilian becomes an unprivileged belligerent by engaging in combat against coalition forces, and there is no evidence that Hicks fired his weapon (which is why the other charges of attempted murder were dropped by the court for lack of evidence). Normally you cannot classify a civilain as an unpriviliged belligerent simply because he planned or trained to engage in combat. He actually has to fight.
The charge of providing support for a terroist organization clearly breaks some new ground here, and maybe it will not stand up to review. But the charge has to be evaluated in the proper context, and cannot simply be dismissed because it is not one that could be made against a privileged combatant. Hicks clearly could not have been tried in a US court because he was captured outside US civilian jurisdiction and is not a US citizen (unlike Jose Padilla who will go on trial next month for the exact same charge but based on acts committed in Afghanistan when he was a civilian and a US citizen). That Hicks was present on the battlefield may give MCA jurisdiction to try civilians for civilian crimes, but clearly this can be disputed.
This smells like a plea deal to save face for the prosecution. Let's see how Hicks is treated Down Under.
Before talking about "brilliant defense maneuver", remember there is nothing currently before the court that is legally or procedurally different from what would have been resolved for Hicks three years ago if his defense had skipped the Hamdan challege to the original military commission. He could have made the same deal, and he would still have been able to raise the same issues on appeal. All the defense accomplished was delay, while their client sat several years longer in Guantanamo.
Hicks clearly could not have been tried in a US court because he was captured outside US civilian jurisdiction and is not a US citizen
This is incorrect. The federal statute creating the crime of providing material support to a designated foreign terrorist organization (18 U.S.C. 2339B) expressly provides that there is jurisdiction over the offense if "after the conduct required for the offense occurs an offender is brought into or found in the United States, even if the conduct required for the offense occurs outside the United States." 18 U.S.C. 2339B(d)(1)(C). There thus was no jurisdictional impediment to prosecuting Hicks in federal court.
A few observations, if I may:
1) I doubt that Mr. Hicks' sentence can be appealed. It appears that Hicks has entered into a plea bargain to plead guilty to a lesser charge of providing material support for terrorism. Although the reported terms of this plea bargain are very hazy, generally a defendant which enters a guilty plea waives his or her right to appeal as part of the plea bargain. I would be very surprised if the military did not insist on such a waiver, especially if they are giving up custody of Hicks to Australia.
2) I would be further surprised if the Australian courts declined to recognize a waiver of appeal out of comity for the United States courts. It appears that the military judge in this case is going through the usual colloquy to ensure that Mr. Hicks' plea is knowing and voluntary. Further, the Australian court will also be well aware that this plea bargain was the product of a great deal of careful diplomacy. While an Australian court ruling that the plea bargain was illegal followed by a release of Mr. Hicks may cause some fleeting embarrassment for the US, such a ruling will definitely guarantee that future unlawful enemy combatants will not be turned over to foreign custody.
3) You bring up a very interesting issue concerning the origins and application of the substantive law of war as it applies to unlawful enemy combatants. I would suggest that the MCA express definition of offenses for which an unlawful enemy combatant may be punished simply codifies pre-existing military custom for the treatment of unlawful enemy combatants.
Previously in our history, the President or the military custom set forth definitions of what constituted an unlawful enemy combatant. For example, Section IV of Lincoln's General Order No. 100 dated April 23, 1863 defined unlawful enemy combatants in ways which would cover the acts committed by Mr. Hicks:
SECTION IV.--Partisans--Armed enemies not belonging to the hostile army--Scouts--Armed prowlers-- War-rebels.
82. Men, or squads of men, who commit hostilities, whether by fighting, or inroads for destruction or plunder, or by raids of any kind, without commission, without being part and portion of the organized hostile army, and without sharing continuously in the war, but who do so with intermitting returns to their homes and avocations, or with the occasional assumption of the semblance of peaceful pursuits, divesting themselves of the character or appearance of soldiers--such men, or squads of men, are not public enemies, and therefore, if captured, are not entitled to the privileges of prisoners of war, but shall be treated summarily as highway robbers or pirates.
83. Scouts or single soldiers, if disguised in the dress of the country, or in the uniform of the army hostile to their own, employed in obtaining information, if found within or lurking about the lines of the captor, are treated as spies, and suffer death.
84. Armed prowlers, by whatever names they may be called, or persons of the enemy's territory, who steal within the lines of the hostile army for the purpose of robbing, killing, or of destroying bridges, roads, or canals, or of robbing or destroying the mail, or of cutting the telegraph wires, are not entitled to the privileges of the prisoner of war.
Under such definitions, the military could and did execute unlawful enemy combatants after a status review which varied between a summary battlefield determination to something approaching a military trial. Consequently, a simple determination of status was enough to impose the full range of punishments up to and including death.
I would suggest that the war crimes enumerated by the MCA are simply codifications of the acts which the military has previously used to determine whether a capture was an unlawful enemy combatant subject to punishment. Under such an interpretation, ex post facto arguably should not come into play.
Normally you cannot classify a civilain as an unpriviliged belligerent simply because he planned or trained to engage in combat. He actually has to fight.
Good thing for the Michigan Militia et.al., eh? Would kind of ruin their Sunday "shoot a gopher with an M-16" parties....
Your average defense atty could point to lots of examples of something similar occurring, many legally innocent people languishing in jails alone waiting for trials. Such jails aren't Gitmo, but they aren't nice places either.
"I doubt that Mr. Hicks' sentence can be appealed."
In fact the plea (and the sentence, which hasn't been imposed yet, obviously) can probably be appealed. At least in federal habeas (which Hicks aims for, if I understand correctly), pleading guilty or n.c. precludes 2255 motions alleging a denial of rights prior to the plea, but does not waive relief for deprivations of rights affecting the validity of the plea itself, including the denial or IAC of counsel or other due process violations. Timmreck US '79. I'd expect the same doctrine to hold even in a sham petition or appeal from a sham trial.
"Bart" DePalma muses:
1) I doubt that ...
2) I would be further surprised if ...
A lot of things surprise "Bart" ... like reality. When he has difficulty describing what happened in cases that have occured in the past (such as his Briwn II hallucinations and his repeated assertions that the U.S. Supreme Court had held that the N.Y. Times could be prosecuted post-publication in the Pentagon Papers case), his blatherings aon what courts are going to decide in the future should be cause for amusement and not much more.
... While an Australian court ruling that the plea bargain was illegal followed by a release of Mr. Hicks may cause some fleeting embarrassment for the US, such a ruling will definitely guarantee that future unlawful enemy combatants will not be turned over to foreign custody.
See what I was saying about "Bart"'s tenuous grasp on reality? Hey, "Bart": Happen to know where Hamdi is?
It appears that the military judge in this case is going through the usual colloquy to ensure that Mr. Hicks' plea is knowing and voluntary.
Perhaps won't matter much if Hicks has been denied legal counsel of his choice as the Geneva Conventions [GC3, Article 105 and GC4, Article 72] require for detainees (or there are other procedural bars to finding he got a fair trial). If his trial was flawed, so is his plea.
I would suggest that the MCA express definition of offenses for which an unlawful enemy combatant may be punished simply codifies pre-existing military custom for the treatment of unlawful enemy combatants.
Oh. My bad. I though you'd claimed that we used to just summarily shoot them. Or did I miss the part the the MCA that says they may do that?
Under such definitions, the military could and did execute unlawful enemy combatants after a status review which varied between a summary battlefield determination to something approaching a military trial.
As was pointed out, about the only instances of summary executions in the study you cited was of the Nazis and Japanese doing such in WWII. Hardly an authority to cite to.
"I doubt that Mr. Hicks' sentence can be appealed."
In fact the plea (and the sentence, which hasn't been imposed yet, obviously) can probably be appealed. At least in federal habeas...
Unless the Court reverses the MCA, Mr. Hicks has no habeas rights before US federal courts.
Here is a short review of appeal waivers in plea bargains offered by the US Attorneys Manual:
626 Plea Agreements and Sentencing Appeal Waivers -- Discussion of the Law
At the outset, it is important to note that the Supreme Court has repeatedly held that a criminal defendant can elect to waive many important constitutional and statutory rights during the plea bargaining process. See United States v. Mezzanatto, 115 S. Ct. 797, 801 (1995); Tollett v. Henderson, 411 U.S. 258, 267 (1973); Blackledge v. Allison, 431 U.S. 63, 71 (1977, cert. denied, 116 S. Ct. 548 (1995). Consistent with that principle, the courts of appeals have upheld the general validity of a sentencing appeal waiver in a plea agreement. See, e.g., United States v. Allison, 59 F.3d 43, 46 (6th Cir. 1995); United States v. Schmidt, 47 F.3d 188, 190 (7th Cir. 1995); United States v. Attar, 38 F.3d 727, 731 (4th Cir. 1994), cert denied, 115 S. Ct. 1957 (1995); United States v. Bushert, 997 F.2d 1343, 1350 (11th Cir. 1993), cert. denied, 115 S. Ct. 652 (1994); United States v. DeSantiago-Martinez, 980 F.2d 582, 583 (9th Cir. 1992), amended, 38 F.3d 394 (1994), cert. denied, 115 S. Ct. 939 (1995); United States v. Melancon, 972 F.2d 566, 567-568 (5th Cir. 1992); United States v. Rivera, 971 F.2d 876, 896 (2d Cir. 1992); United States v. Rutan, 956 F.2d 827, 829-830 (8th Cir. 1992).
A sentencing appeal waiver provision does not waive all claims on appeal. The courts of appeals have held that certain constitutional and statutory claims survive a sentencing appeal waiver in a plea agreement. For example, a defendant's claim that he or she was denied the effective assistance of counsel at sentencing, United States v. Attar, supra; that he or she was sentenced on the basis of race, United States v. Jacobson, 15 F.3d 19 (2d Cir. 1994); or that the sentence exceeded the statutory maximum, United States v. Marin, 961 F.2d 493, 496 (4th Cir. 1992), will be reviewed on the merits by a court of appeals despite the existence of a sentencing appeal waiver in a plea agreement.
The only basis given above for Mr. Hicks to appeal would be ineffective assistance of counsel, which is not what Professor Glazier hopes would be appealed.
how about ineffective assistance of counsel due to the unlawful exclusion of hicks' chosen counsel by the military commission?
how about ineffective assistance of counsel due to the unlawful exclusion of hicks' chosen counsel by the military commission?
I didn't have the time to address that in my last post.
To start, I am unsure whether Hicks can make an ineffective assistance of counsel claim. Hicks arguably has no constitutional rights in this regard pursuant to the ruling in Ex Parte Quirin, where the Court held that unlawful enemy belligerents do not enjoy 5th and 6th Amendment rights.
If Hicks does enjoy a right to effective counsel, I am unsure to what extent his civilian counsel were even involved in this plea agreement. I believe it was reported that the military judge discussed with Hicks whether the expulsion of his civilian counsel affected his decision to accept the plea offer and plead guilty and Hicks said it did not. It appears that the military judge is attempting to dot the I's and cross the T's in this plea agreement.
"Bart" DePalma is clueless and reading-impaired once again:
[from the USA manual]: A sentencing appeal waiver provision does not waive all claims on appeal. The courts of appeals have held that certain constitutional and statutory claims survive a sentencing appeal waiver in a plea agreement. For example, a defendant's claim that he or she was denied the effective assistance of counsel at sentencing, United States v. Attar, supra; that he or she was sentenced on the basis of race, United States v. Jacobson, 15 F.3d 19 (2d Cir. 1994); or that the sentence exceeded the statutory maximum, United States v. Marin, 961 F.2d 493, 496 (4th Cir. 1992), will be reviewed on the merits by a court of appeals despite the existence of a sentencing appeal waiver in a plea agreement.
The only basis given above for Mr. Hicks to appeal would be ineffective assistance of counsel, which is not what Professor Glazier hopes would be appealed.
Missed that "for example", didja, "Bart"? That doesn't mean, despite your insinuations or your wet dreams, that "the only such situations are as follows".
Thanks for admitting that Rothmatisseko and I were right, though, in saying that you were full'o'it when you said that "I doubt that Mr. Hicks' sentence can be appealed".
The Australian courts, actually, have a doctrine you'd probably recognise as the 'unitary judiciary' which takes a very dim view of executive tribunals masquerading as courts and an equally dim view of the executive attempting to disregard the rule of law or pre-empt the courts from their constitutional role by diplomatic agreement. See, for example, Polyukhovich v Commonwealth, Ex parte Boilermakers’ Society of Australia or Communist Party of Australia v Commonwealth .
There's a reason the Howard Government is desperate for this matter not to come before an Australian court until the federal election.
I believe it was reported that the military judge discussed with Hicks whether the expulsion of his civilian counsel affected his decision to accept the plea offer and plead guilty and Hicks said it did not.
If it's been "reported", cite it. We just don't trust you on anything around here (and for good reasons which I've repeatedly demonstrated).
As for Hicks telling da judge that it was no matter if his civilain counsel was expelled: Think, man, think! Here's a guy pleading guilty perhaps because his prosecutors appointed his lawyer (and consider what happened with Lt. Cmdr. Swift, who was pressured by the military to get Salim to plead guilty). So, "Bart" thinks that this guy, sans the attorney he wanted, can "cure" this defect by telling the judge (without access to or advice from said lawyer) that it's no big deal he didn't get his lawyer.
Joseph Heller had nothing on the ol' "Bartster".....
Re: my last post
After posting it, I came to realise that "Bart" probably still won't understand WTF I was saying (if he even bothers to read it).
DAVID Hicks' lawyers will seek his immediate release from any Australian prison if he is returned to Australia to serve more time in jail.
Victorian barrister Brian Walters, SC, has advised the Australian's legal team that to keep Hicks in continued detention in Australia would be unconstitutional because Australian courts could not recognise the new US military commissions.
Mr Walters and Robert Richter, QC, both said a prisoner transfer agreement signed by the US and Australia contained a little-known clause allowing lawyers to challenge the US sentence in an Australian court.
Attorney-General Philip Ruddock yesterday denied the transfer agreement allowed an Australian court to alter the length of a sentence imposed by the US.
"International transfer agreements are not to provide a lesser penalty than would be served if the person remained in the jurisdiction where the conviction was obtained," Mr Ruddock said.
"The principle is very clear: if a country were to unilaterally vary a sentence imposed on an individual in another jurisdiction, no country would deliver anybody up."
But under the transfer agreement, signed on May 9 last year, an Australian court has the power to re-set the US military commission sentence if it is "by its nature or duration incompatible with the law of Australia".
"I cannot see the legal basis for holding him (Hicks) in Australia," Mr Walters said.
An appeal before Australian courts was inevitable if Hicks faced continued imprisonment here.
"I do not believe that the courts in Australia will provide recognition to any sentence imposed by the military commission."
Mr Walters said: "If the agreement were that an Australian citizen would serve their sentence in Australia, this would only achieve recognition by Australian courts where the person had been sentenced by a properly constituted court.
"The military commissions at Guantanamo Bay plainly do not qualify: a mere presidential order that someone be detained could not justify the deprivation of liberty in Australia."
S4A of the International Transfer of Prisoners Act 1997 starkly shows quite how slavish the Howard government has been towards the Bush administration.
'Sentences of imprisonment imposed by military commissions of the United States of America
For the purposes of this Act:
(a) a military commission of the United States of America is taken to be a court or tribunal of the United States of America; and
(b) any punishment or measure involving deprivation of liberty ordered by a military commission of the United States of America is taken to have been ordered by a court or tribunal of the United States of America in the exercise of its criminal jurisdiction; and
(c) any direction or order given or made by a military commission of the United States of America with respect to the commencement of such punishment or measure is taken to have been given or made by a court or tribunal of the United States of America.'
Despite that, the High Court has consistently read down privative clauses like this and the section would certainly not survive an adverse finding by the US Supreme Court, if the High Court did not, of its own motion, hold the section contrary to the Polyukhovich doctrine. It's also exceedingly likely that there will be a change of government at the next federal election which is due by the end of the year. The opposition would almost certainly repeal S4.
If Australian courts unilaterally release a convicted and admitted terrorist entrusted to their care, the opponents of Gitmo have just made the case that there is no viable alternative to that facility.
Could that be the purpose of this transfer?
If the High Court of Australia held that S4A is beyond the powers of the Federal Parliament then Hicks would not be a convicted and admitted terrorist in terms of Australian law. The admission is questionable under US law and would be unlawful in terms of Australian law.
The relevant Australian law is discussed in a speech (pdf) at the University of the Witwatersrand by Justice Michael Kirby in 2005. The Law Council of Australia issued an advice (pdf) on 8 March which reads in part:
'Accordingly, and on all three grounds consistently applied by the Supreme Court of the United States, the offence created by Section 950v(25) MCA, when applied to the activities of David Hicks in Afghanistan between December 2000 to December 2001 is a clear and straightforward case of a retrospective criminal law. As such it is a classic retrospective (ex post facto) offence within at least three of the Calder v Bull categories of unlawful criminal legislation. Consequently, it is prohibited by the Constitution of the United States of America and also violates treaties to which Australia and the United States are parties, namely Article 99 GC3 and Article 15 of the ICCPR and contravenes the Australian Criminal Code.
The attempt to apply the section 950v(25) MCA offence to Hicks plainly violates the substance of the guarantee against ex post facto laws in the US Constitution. The provision is therefore unconstitutional and invalid on its face. The only doubt relates to whether Hicks, as a non-citizen held outside the sovereign territory of the United States, has the standing to seek a remedy before the US federal courts for the violation of the principle of non-retrospectivity. Until this question has finally been determined by the US Supreme Court, in practical terms, there is no constitutional obstacle in the United States to applying a retrospective criminal law to David Hicks, although this could not happen legally to any citizen of the United States.
The suggestion that the offence of Providing Material Support for Terrorism under the MCA is merely a codification of an existing Law of War or an existing domestic law of the United States, and is therefore not a retrospective criminal law, is untenable. This is a recently invented and new war crime created with the passing of the Military Commissions Act of 2006 on 17 October 2006.'
I would be not surprised, but astonished, if the Australian courts disregarded the Constitution and the laws of Australia as matter of diplomatic convenience.
"Bart" DePalma, meet Humpty-Dumpty:
If Australian courts unilaterally release a convicted and admitted terrorist entrusted to their care, the opponents of Gitmo have just made the case that there is no viable alternative to that facility.
"'When I use a word,' Humpty Dumpty said, in rather a scornful tone, 'it means just what I choose it to mean -- neither more nor less.'"
To be sure, Hicks is not a person I'd want staying at my house (but that goes also for the guys that Blackwater hires). But if laws are to mean something, we have to know what the parameters are. The mealy-mouthed "providing material support to terrorism" need definition of all those words, and then we should look to see if whether what we come up with deserves to be a crime under those circumstances (disclaimer: I don't know what Hicks [supposedly] did in Afghanistan and when, so I have no real idea as to his criminal or moral culpability in my mind). And then we have to see if what Hicks did fits the law as we agree it should be.
The reason I waffle here on such loosely defined charges is that support to charities has been cited by some as constituting "material support" to "terrorist"). There ought to be a line, and just unknowingly giving money to a purported (or at least partial) charity seems to be somewhat innocuous, and harldy a fit target for gummint terra-ist prosecution; education might be of more use.
At the AIDP Blog (http://www.aidpblog.org), I ask this question in reference to your post:
Omar Khadr previously has stated he will not cooperate with his “infidel pig” lawyer, or the “court of the infidels” which will make for a bit more excitement than the Hicks case.
"...if Hicks was innocent, and his plea was part of a 'brilliant defense maneuver' to get him out of the MC’s and into regular courts, is the opposite true? That is, if Khadr enters a not-guilty plea is his strategy ill conceived? It seems Defense advocates can’t have it both ways and it will be interesting to see how these cases develop."
I look forward to hearing your thoughts.
"the offence created by Section 950v(25) MCA"
The offense mentioned in 950v(21) RAPE or (23) HIJACKING OR HAZARDING A VESSEL OR AIRCRAFT were not created by the MCA. Rather, the MCA grants jurisdiction to the military commission to try the preexisting offense. Which is not to say that (25) PROVIDING MATERIAL SUPPORT FOR TERRORISM definitely preexisted. However, in a previous post Madisonian noted:
"The federal statute creating the crime of providing material support to a designated foreign terrorist organization (18 U.S.C. 2339B) expressly provides that there is jurisdiction over the offense if "after the conduct required for the offense occurs an offender is brought into or found in the United States, even if the conduct required for the offense occurs outside the United States." 18 U.S.C. 2339B(d)(1)(C). There thus was no jurisdictional impediment to prosecuting Hicks in federal court."
So to assert that there was no preexisting crime to which the MCA could assign jurisdiction, you have to compare the date of the offense to the legislative history of "material support" offenses.
[Wish one could edit previous post]. Upon examination of the charging document against Hicks, it is clear that he was charged with violation of 950v(25). See page 6 of 9 in:
So it appears that either he was charged ex post facto or else the formal charge sheet was defective and referenced a violation of the jurisdictional grant instead of the underlying criminal offense.
I'm not sure what you mean when you say "he was charged ex post facto." If you look at sec. 950p of the MCA, it expressly provides that the statute's purposes was to "codify offenses that have traditionally been triable by military commissions." Thus, the Act did not intend to create new crimes; instead, the goal was to enumerate specific traditional law of war violations that the new commissions would be given jurisdiction to try. To be sure, one can take (and many have taken) issue with the Act's bare assertion that the material support offense was actually an established violation of the laws of war. But that's just to say that the legal dispute about the validity of the charge reduces to a factual question about whether the material support offense existed in 2001 -- not (mind you)as a violation of federal law, but rather as a violation of international law. An interesting subsidiary question in light of sec. 950p is whether Congress' assertion that it did exist is entitled to any deference by the courts (whether in the United States or in Australia).
It is pretty clear that "material support for a terrorist organization" was a well defined US civilian crime. However, at various times the US has supported al Qaeda (against the Russians), the Contras, Cuban groups, French resistance, Tito Partisans, Philippines. You would like the irregulars to only kill enemy soldiers, but you typically cannot control them, and in a war we don't cut off support for an ally when they exceed our view of proper behavior.
Part of the problem is some confusion between "violations of the laws of war", "war crimes", and "offenses normally triable in a military tribunal". They are different things.
Hicks says he wasn't a soldier, and we appear to agree with that. I don't think you can charge a civilian with a "war crime", and in very few cases (when he acts as a spy on behalf of the enemy military commanders) can he violate the laws of war. Mostly civilians just commit ordinary crimes. Even when they engage in combat with your troops it is just called "murder" or "attempted murder", charges made against Hicks but dismissed for lack of evidence. When ordinary crimes occur in an area of combat or military occupation, the military can detain civilians and military courts can and routinely do hear charges of murder, rape, and other crimes that occur within their area of operations.
So I can see an argument that the civilian Hicks committed a civilian crime and fell within military jurisdiction because he was captured on the battlefield, and that the military commission has now been authorized to try him for that crime. I would just like to see an explicit reference to underlying criminal statute.
However, given that one man's terrorist is another man's freedom fighter, if we argue that material support for terrorists is a war crime or violation of the laws of war, then we have a bunch of explaining to do for our own past actions, and future US military forces will have a hard time avoiding the same charge if we have anything to do with irregular allied forces.
future US military forces will have a hard time avoiding the same charge if we have anything to do with irregular allied forces....
Like, oh say, the Contras. Or the Northern Alliance. Or D'Aubuisson's death squads. Hell, read Stephen Kinzer's fine book, "Overthrow" for a hudred-year list of the atrocities.
Madision says that: "The federal statute creating the crime of providing material support to a designated foreign terrorist organization (18 U.S.C. 2339B) expressly provides that there is jurisdiction over the offense if "after the conduct required for the offense occurs an offender is brought into or found in the United States, even if the conduct required for the offense occurs outside the United States." 18 U.S.C. 2339B(d)(1)(C). There thus was no jurisdictional impediment to prosecuting Hicks in federal court."
This provision was inserted in 2004 by PL 108-458. In 2001, s2339B applied only to people within the US or subject to the jurisdiction of the US. Further, the 2004 amendment requires the offender to be brought within the US. Of course, David Hicks only made it as far as Guantanamo Bay. Furthermore, the definition of "material support" as it stood in 2001 covered currency and other financial securities, financial services, lodging, training, expert advice or assistance, etc, etc. None of the things alleged against David Hicks appears to satisfy that definition. He has, for example, admitted to receiving training, not providing it..
The Australian Government refused to request Hicks' return to Australia on the basis of legal advice from the Australian DPP that he had committed no offence against Australian law. It said that it was not prepared to pass retrospective legislation to try him in Australia. It was, however, prepared to allow the US to do so.
Finally, the deal offered to Hicks on Moday wsa not available three years ago, when he was charged with conspiracy and attempted murder. There has clearly been huge political pressure geared to the Australian federal election to get Hicks home and have him released by the end of the year. The alternative was for the Australian government to request his immediate return - as the British government did in relation to its citizen Abassi, named as an associate of Hicks in the training camps in Afghanistan. That would have been embarrassing for Howard and Bush.
A very interesting blog. Some commentators have said it is unlikely that Australian courts will look into the plea agreement (on the grounds of comity).
You all might be interested in the following interlocutory judgment of the Federal Court of Australia involving Hicks (handed down earlier this year): Hicks v Ruddock  FCA 299 (http://www.austlii.edu.au/au/cases/cth/federal_ct/2007/299.html).
It shows our courts aren't to afraid to delve into political issues.
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In 2007, under a pre-trial agreement with convening authority Judge Susan J. Crawford, Hicks pled guilty before a United States military tribunal to a newly codified charge of "providing material support for terrorism" and was returned to Australia to serve the remaining nine months of a mostly suspended seven-year sentence. sportsbook, This nine month period precluded media contact and drew criticism for delaying his release until after the 2007 Australian election. Hicks' detention without charge, the subsequent trial process and outcome, and the newly created legal system under which these events took place, drew widespread criticisms. http://www.enterbet.com
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mesothelioma The symptoms of
mesothelioma include shortness of breath due to pleural effusion (fluid between the lung and the chest wall or chest wall pain, and general symptoms such as weight loss. The diagnosis may be suspected with chest X-ray and CT scan and is confirmed with a biopsy (tissue sample) and microscopic examination. A thoracoscopy inserting a tube with a camera into the chest) can be used to take biopsies. It allows the introduction of substances such as talc to obliterate the pleural space (called pleurodesis, which prevents more fluid from accumulating and pressing on the lung. Despite treatment with chemotherapy, radiation therapy or sometimes surgery, the disease carries a poor prognosis. Research about screening tests for the early detection of mesothelioma is ongoing.
Symptoms of mesothelioma may not appear until 20 to 50 years after exposure to asbestos. Shortness of breath, cough, and pain in the chest due to an accumulation of fluid in the pleural space are often symptoms of pleural
mesotheliomaSymptoms of peritoneal
mesothelioma include weight loss and cachexia, abdominal swelling and pain due to ascites (a buildup of fluid in the abdominal cavity). Other symptoms of peritoneal
mesothelioma may include bowel obstruction, blood clotting abnormalities, anemia, and fever. If the cancer has spread beyond the mesothelium to other parts of the body, symptoms may include pain, trouble swallowing, or swelling of the neck or face.
These symptoms may be caused by
mesothelioma or by other, less serious conditions.
Mesothelioma that affects the pleura can cause these signs and symptoms:
chest wall pain
pleural effusion, or fluid surrounding the lung
shortness of breath
fatigue or anemia
wheezing, hoarseness, or cough
blood in the sputum (fluid) coughed up hemoptysis
In severe cases, the person may have many tumor masses. The individual may develop a pneumothorax, or collapse of the lung The disease may metastasize, or spread, to other parts of the body.
Tumors that affect the abdominal cavity often do not cause symptoms until they are at a late stage. Symptoms include:
ascites, or an abnormal buildup of fluid in the abdomen
a mass in the abdomen
problems with bowel function
In severe cases of the disease, the following signs and symptoms may be present:
blood clots in the veins, which may cause thrombophlebitis
disseminated intravascular coagulation a disorder causing severe bleeding in many body organs
jaundice, or yellowing of the eyes and skin
low blood sugar level
pulmonary emboli, or blood clots in the arteries of the lungs
mesothelioma does not usually spread to the bone, brain, or adrenal glands. Pleural tumors are usually found only on one side of the lungs
mesothelioma is often difficult, because the symptoms are similar to those of a number of other conditions. Diagnosis begins with a review of the patient's medical history. A history of exposure to asbestos may increase clinical suspicion for
mesothelioma A physical examination is performed, followed by chest X-ray and often lung function tests. The X-ray may reveal pleural thickening commonly seen after asbestos exposure and increases suspicion of
mesothelioma A CT (or CAT) scan or an MRI is usually performed. If a large amount of fluid is present, abnormal cells may be detected by cytology if this fluid is aspirated with a syringe. For pleural fluid this is done by a pleural tap or chest drain, in ascites with an paracentesis or ascitic drain and in a pericardial effusion with pericardiocentesis. While absence of malignant cells on cytology does not completely exclude
mesothelioma it makes it much more unlikely, especially if an alternative diagnosis can be made (e.g. tuberculosis, heart failure
If cytology is positive or a plaque is regarded as suspicious, a biopsy is needed to confirm a diagnosis of
mesothelioma A doctor removes a sample of tissue for examination under a microscope by a pathologist. A biopsy may be done in different ways, depending on where the abnormal area is located. If the cancer is in the chest, the doctor may perform a thoracoscopy. In this procedure, the doctor makes a small cut through the chest wall and puts a thin, lighted tube called a thoracoscope into the chest between two ribs. Thoracoscopy allows the doctor to look inside the chest and obtain tissue samples.
If the cancer is in the abdomen, the doctor may perform a laparoscopy. To obtain tissue for examination, the doctor makes a small incision in the abdomen and inserts a special instrument into the abdominal cavity. If these procedures do not yield enough tissue, more extensive diagnostic surgery may be necessary.
There is no universally agreed protocol for screening people who have been exposed to
asbestosScreening tests might diagnose mesothelioma earlier than conventional methods thus improving the survival prospects for patients. The serum osteopontin level might be useful in screening asbestos-exposed people for
mesotheliomaThe level of soluble mesothelin-related protein is elevated in the serum of about 75% of patients at diagnosis and it has been suggested that it may be useful for screening. Doctors have begun testing the Mesomark assay which measures levels of soluble mesothelin-related proteins (SMRPs) released by diseased mesothelioma cells
Although reported incidence rates have increased in the past 20 years, mesothelioma is still a relatively rare cancer. The incidence rate is approximately one per 1,000,000. The highest incidence is found in Britain, Australia and Belgium: 30 per 1,000,000 per year. For comparison, populations with high levels of smoking can have a lung cancer incidence of over 1,000 per 1,000,000. Incidence of malignant mesothelioma currently ranges from about 7 to 40 per 1,000,000 in industrialized Western nations, depending on the amount of asbestos exposure of the populations during the past several decades. It has been estimated that incidence may have peaked at 15 per 1,000,000 in the United States in 2004. Incidence is expected to continue increasing in other parts of the world. Mesothelioma occurs more often in men than in women and risk increases with age, but this disease can appear in either men or women at any age. Approximately one fifth to one third of all mesotheliomas are peritoneal.
Between 1940 and 1979, approximately 27.5 million people were occupationally exposed to asbestos in the United States.[ Between 1973 and 1984, there has been a threefold increase in the diagnosis of pleural mesothelioma in Caucasian males. From 1980 to the late 1990s, the death rate from mesothelioma in the USA increased from 2,000 per year to 3,000, with men four times more likely to acquire it than women. These rates may not be accurate, since it is possible that many cases of mesothelioma are misdiagnosed as adenocarcinoma of the lung, which is difficult to differentiate from mesothelioma.
Working with asbestos is the major risk factor for mesothelioma. A history of asbestos exposure exists in almost all cases. However, mesothelioma has been reported in some individuals without any known exposure to asbestos. In rare cases, mesothelioma has also been associated with irradiation, intrapleural thorium dioxide (Thorotrast), and inhalation of other fibrous silicates, such as erionite.
is the name of a group of minerals that occur naturally as masses of strong, flexible fibers that can be separated into thin threads and woven.
has been widely used in many industrial products, including cement, brake linings, roof shingles, flooring products, textiles, and insulation. If tiny asbestos particles float in the air, especially during the manufacturing process, they may be inhaled or swallowed, and can cause serious health problems. In addition to mesothelioma, exposure to asbestos increases the risk of lung cancer, asbestosis (a noncancerous, chronic lung ailment), and other cancers, such as those of the larynx and kidney.
The combination of smoking and
asbestos exposure significantly increases a person's risk of developing cancer of the airways (lung cancer bronchial carcinoma). The Kent brand of cigarettes used
mesothelioma in its filters for the first few years of production in the 1950s and some cases of
mesothelioma have resulted. Smoking modern cigarettes does not appear to increase the risk of mesothelioma.
Some studies suggest that simian virus 40 may act as a cofactor in the development of mesothelioma.
Asbestos was known in antiquity, but it wasn't mined and widely used commercially until the late 1800s. Its use greatly increased during World War II Since the early 1940s, millions of American workers have been exposed to asbestos dust. Initially, the risks associated with
asbestos exposure were not publicly known. However, an increased risk of developing mesothelioma was later found among shipyard workers, people who work in asbestos mines and mills, producers of asbestos products, workers in the heating and construction industries, and other tradespeople. Today, the U.S. Occupational Safety and Health Administration (OSHA) sets limits for acceptable levels of
asbestos exposure in the workplace, and created guidelines for engineering controls and respirators, protective clothing, exposure monitoring, hygiene facilities and practices, warning signs, labeling, recordkeeping, and medical exams. By contrast, the British Government's Health and Safety Executive (HSE) states formally that any threshold for
mesothelioma must be at a very low level and it is widely agreed that if any such threshold does exist at all, then it cannot currently be quantified. For practical purposes, therefore, HSE does not assume that any such threshold exists. People who work with
asbestos wear personal protective equipment to lower their risk of exposure. Recent findings have shown that a mineral called erionite has been known to cause genetically pre-dispositioned individuals to have malignant mesothelioma rates much higher than those not pre-dispositioned genetically. A study in Cappadocia, Turkey has shown that 3 villiages in Turkey have death rates of 51% attributed to erionite related
asbestos fibres has been recognised as an occupational health hazard since the early 1900s. Several epidemiological studies have associated exposure to asbestos with the development of lesions such as asbestos bodies in the sputum, pleural plaques, diffuse pleural thickening, asbestosis, carcinoma of the lung and larynx, gastrointestinal tumours, and diffuse mesothelioma of the pleura and peritoneum.
The documented presence of
asbestos fibres in water supplies and food products has fostered concerns about the possible impact of long-term and, as yet, unknown exposure of the general population to these fibres. Although many authorities consider brief or transient exposure to
asbestos fibres as inconsequential and an unlikely risk factor, some epidemiologists claim that there is no risk threshold. Cases of mesothelioma have been found in people whose only exposure was breathing the air through ventilation systems. Other cases had very minimal (3 months or less) direct exposure.
asbestos mining at Wittenoom, Western Australia, occurred between 1945 and 1966. A cohort study of miners employed at the mine reported that while no deaths occurred within the first 10 years after crocidolite exposure, 85 deaths attributable to mesothelioma had occurred by 1985. By 1994, 539 reported deaths due to mesothelioma had been reported in Western Australia.
Family members and others living with
asbestos workers have an increased risk of developing
mesothelioma and possibly other asbestos related diseases. This risk may be the result of exposure to
asbestos dust brought home on the clothing and hair of
asbestos workers. To reduce the chance of exposing family members to asbestosMany building materials used in both public and domestic premises prior to the banning of
asbestos may contain
asbestos Those performing renovation works or activities may expose themselves to asbestos dust. In the UK use of Chrysotile asbestos was banned at the end of 1999. Brown and blue
asbestos was banned in the UK around 1985. Buildings built or renovated prior to these dates may contain asbestos materials.
For patients with localized disease, and who can tolerate a radical surgery, radiation is often given post-operatively as a consolidative treatment. The entire hemi-thorax is treated with radiation therapy, often given simultaneously with chemotherapy. Delivering radiation and chemotherapy after a radical surgery has led to extended life expectancy in selected patient populations with some patients surviving more than 5 years. As part of a curative approach to
mesothelioma radiotherapy is also commonly applied to the sites of chest drain insertion, in order to prevent growth of the tumor along the track in the chest wall.
mesothelioma is generally resistant to curative treatment with radiotherapy alone, palliative treatment regimens are sometimes used to relieve symptoms arising from tumor growth, such as obstruction of a major blood vessel.
Radiation Therapy when given alone with curative intent has never been shown to improve survival from
mesothelioma The necessary radiation dose to treat mesothelioma that has not been surgically removed would be very toxic.
Chemotherapy is the only treatment for
mesothelioma that has been proven to improve survival in randomised and controlled trials. The landmark study published in 2003 by Vogelzang and colleagues compared cisplatin chemotherapy alone with a combination of cisplatin and pemetrexed (brand name Alimta) chemotherapy) in patients who had not received chemotherapy for malignant pleural mesothelioma previously and were not candidates for more aggressive "curative" surgery. This trial was the first to report a survival advantage from chemotherapy in malignant pleural
mesothelioma showing a statistically significant improvement in median survival from 10 months in the patients treated with cisplatin alone to 13.3 months in the combination pemetrexed group in patients who received supplementation with folate and vitamin B12. Vitamin supplementation was given to most patients in the trial and pemetrexed related side effects were significantly less in patients receiving pemetrexed when they also received daily oral folate 500mcg and intramuscular vitamin B12 1000mcg every 9 weeks compared with patients receiving pemetrexed without vitamin supplementation. The objective response rate increased from 20% in the cisplatin group to 46% in the combination pemetrexed group. Some side effects such as nausea and vomiting, stomatitis, and diarrhoea were more common in the combination pemetrexed group but only affected a minority of patients and overall the combination of pemetrexed and cisplatin was well tolerated when patients received vitamin supplementation; both quality of life and lung function tests improved in the combination pemetrexed group. In February 2004, the United States Food and Drug Administration approved pemetrexed for treatment of malignant pleural mesothelioma. However, there are still unanswered questions about the optimal use of chemotherapy, including when to start treatment, and the optimal number of cycles to give.
Cisplatin in combination with raltitrexed has shown an improvement in survival similar to that reported for pemetrexed in combination with cisplatin, but raltitrexed is no longer commercially available for this indication. For patients unable to tolerate pemetrexed, cisplatin in combination with gemcitabine or vinorelbine is an alternative, although a survival benefit has not been shown for these drugs. For patients in whom cisplatin cannot be used, carboplatin can be substituted but non-randomised data have shown lower response rates and high rates of haematological toxicity for carboplatin-based combinations, albeit with similar survival figures to patients receiving cisplatin.
In January 2009, the United States FDA approved using conventional therapies such as surgery in combination with radiation and or chemotherapy on stage I or II Mesothelioma after research conducted by a nationwide study by Duke University concluded an almost 50 point increase in remission rates.
Treatment regimens involving immunotherapy have yielded variable results. For example, intrapleural inoculation of Bacillus Calmette-Guérin (BCG) in an attempt to boost the immune response, was found to be of no benefit to the patient (while it may benefit patients with bladder cancer.
mesothelioma cells proved susceptible to in vitro lysis by LAK cells following activation by interleukin-2 (IL-2), but patients undergoing this particular therapy experienced major side effects. Indeed, this trial was suspended in view of the unacceptably high levels of IL-2 toxicity and the severity of side effects such as fever and cachexia. Nonetheless, other trials involving interferon alpha have proved more encouraging with 20% of patients experiencing a greater than 50% reduction in tumor mass combined with minimal side effects.
A procedure known as heated intraoperative intraperitoneal chemotherapy was developed by at the Washington Cancer Institute. The surgeon removes as much of the tumor as possible followed by the direct administration of a chemotherapy agent, heated to between 40 and 48°C, in the abdomen. The fluid is perfused for 60 to 120 minutes and then drained.
This technique permits the administration of high concentrations of selected drugs into the abdominal and pelvic surfaces. Heating the chemotherapy treatment increases the penetration of the drugs into tissues. Also, heating itself damages the malignant cells more than the normal cells.
What is the mesothelium?
The mesothelium is a membrane that covers and protects most of the internal organs of the body. It is composed of two layers of cells: One layer immediately surrounds the organ; the other forms a sac around it. The mesothelium produces a lubricating fluid that is released between these layers, allowing moving organs (such as the beating heart and the expanding and contracting lungs to glide easily against adjacent structures.
The mesothelium has different names, depending on its location in the body. The peritoneum is the mesothelial tissue that covers most of the organs in the abdominal cavity. The pleura is the membrane that surrounds the lungs and lines the wall of the chest cavity. The pericardium covers and protects the heart. The
mesothelioma tissue surrounding the male internal reproductive organs is called the tunica vaginalis testis. The tunica serosa uteri covers the internal reproductive organs in women.
What is mesothelioma?
mesothelioma (cancer of the mesothelium) is a disease in which cells of the mesothelium become abnormal and divide without control or order. They can invade and damage nearby tissues and organs.
cancer cells can also metastasize (spread) from their original site to other parts of the body. Most cases of mesothelioma begin in the pleura or peritoneum.
How common is mesothelioma?
Although reported incidence rates have increased in the past 20 years, mesothelioma is still a relatively rare cancer. About 2,000 new cases of mesothelioma are diagnosed in the United States each year. Mesothelioma occurs more often in men than in women and risk increases with age, but this disease can appear in either men or women at any age.
What are the risk factors for mesothelioma?
Working with asbestos is the major risk factor for mesothelioma. A history of asbestos exposure at work is reported in about 70 percent to 80 percent of all cases. However, mesothelioma has been reported in some individuals without any known exposure to
Asbestos is the name of a group of minerals that occur naturally as masses of strong, flexible fibers that can be separated into thin threads and woven. asbestos has been widely used in many industrial products, including cement, brake linings, roof shingles, flooring products, textiles, and insulation. If tiny asbestos particles float in the air, especially during the manufacturing process, they may be inhaled or swallowed, and can cause serious health problems. In addition to mesothelioma, exposure to asbestos increases the risk of lung cancer, asbestosis (a noncancerous, chronic lung ailment), and other cancers, such as those of the larynx and kidney.
Smoking does not appear to increase the risk of mesothelioma. However, the combination of smoking and asbestos exposure significantly increases a person's risk of developing cancer of the air passageways in the lung.
Who is at increased risk for developing mesothelioma?
asbestos has been mined and used commercially since the late 1800s. Its use greatly increased during World War II. Since the early 1940s, millions of American workers have been exposed to asbestos dust. Initially, the risks associated with asbestos exposure were not known. However, an increased risk of developing mesothelioma was later found among shipyard workers, people who work in asbestos. Today, the U.S. Occupational Safety and Health Administration (OSHA) sets limits for acceptable levels of asbestos exposure in the workplace. People who work with asbestos wear personal protective equipment to lower their risk of exposure.
The risk o f asbestosrelated disease increases with heavier exposure to asbestos and longer exposure time. However, some individuals with only brief exposures have developed mesothelioma On the other hand, not all workers who are heavily exposed develop asbestos-related diseases.
There is some evidence that family members and others living with asbestos workers have an increased risk of developing mesothelioma, and possibly other asbestos-related diseases. This risk may be the result of exposure to
asbestos dust brought home on the clothing and hair of
asbestos workers. To reduce the chance of exposing family members to
asbestos fibers, asbestos workers are usually required to shower and change their clothing before leaving the workplace.
What are the symptoms of mesothelioma?
Symptoms of mesothelioma may not appear until 30 to 50 years after exposure to
asbestos Shortness of breath and pain in the chest due to an accumulation of fluid in the pleura are often symptoms of pleural mesothelioma. Symptoms of peritoneal mesothelioma include weight loss and abdominal pain and swelling due to a buildup of fluid in the abdomen. Other symptoms of peritoneal mesothelioma may include bowel obstruction blood clotting abnormalities, anemia, and fever. If the cancer has spread beyond the mesothelium to other parts of the body, symptoms may include pain, trouble swallowing, or swelling of the neck or face.
These symptoms may be caused by
mesothelioma or by other, less serious conditions. It is important to see a doctor about any of these symptoms. Only a doctor can make a diagnosis
Diagnosing mesothelioma is often difficult, because the symptoms are similar to those of a number of other conditions. Diagnosis begins with a review of the patient's medical history, including any history of asbestos exposure. A complete physical examination may be performed, including x-rays of the chest or abdomen and lung function tests. A CT (or CAT) scan or an MRI may also be useful. A CT scan is a series of detailed pictures of areas inside the body created by a computer linked to an x-ray machine. In an MRI, a powerful magnet linked to a computer is used to make detailed pictures of areas inside the body. These pictures are viewed on a monitor and can also be printed.
A biopsy is needed to confirm a diagnosis of mesothelioma. In a biopsy, a surgeon or a medical oncologist (a doctor who specializes in diagnosing and treating cancer) removes a sample of tissue for examination under a microscope by a pathologist. A biopsy may be done in different ways, depending on where the abnormal area is located. If the
cancer is in the chest, the doctor may perform a thoracoscopy. In this procedure, the doctor makes a small cut through the chest wall and puts a thin, lighted tube called a thoracoscope into the chest between two ribs. Thoracoscopy allows the doctor to look inside the chest and obtain tissue samples. If the
cancer is in the abdomen, the doctor may perform a peritoneoscopy. To obtain tissue for examination, the doctor makes a small opening in the abdomen and inserts a special instrument called a peritoneoscope into the abdominal cavity. If these procedures do not yield enough tissue, more extensive diagnostic surgery may be necessary.
If the diagnosis is mesothelioma, the doctor will want to learn the stage (or extent) of the disease. Staging involves more tests in a careful attempt to find out whether the cancer has spread and, if so, to which parts of the body. Knowing the stage of the disease helps the doctor plan treatment.
Mesothelioma is described as localized if the cancer is found only on the membrane surface where it originated. It is classified as advanced if it has spread beyond the original membrane surface to other parts of the body, such as the lymph nodes, lungs, chest wall, or abdominal organs.
Treatment for mesothelioma depends on the location of the
cancerthe stage of the disease, and the patient's age and general health. Standard treatment options include surgery, radiation therapy, and chemotherapy. Sometimes, these treatments are combined.
Surgery is a common treatment for
mesotheliomaThe doctor may remove part of the lining of the chest or abdomen and some of the tissue around it. For cancer of the pleura (pleural
mesotheliomaa lung may be removed in an operation called a pneumonectomy. Sometimes part of the diaphragm, the muscle below the lungs that helps with breathing, is also removed.
Stereo Tactic Radiation Therapy also called radiotherapy, involves the use of high-energy rays to kill
cancercells and shrink tumors Radiation therapy affects the
cancercells only in the treated area. The radiation may come from a machine (external radiation) or from putting materials that produce radiation through thin plastic tubes into the area where the
cancercells are found (internal radiation therapy).
Chemotherapy is the use of anticancer drugs to kill cancer cells throughout the body. Most drugs used to treat
mesotheliomaare given by injection into a vein (intravenous, or IV). Doctors are also studying the effectiveness of putting chemotherapy directly into the chest or abdomen (intracavitary chemotherapy).
To relieve symptoms and control pain, the doctor may use a needle or a thin tube to drain fluid that has built up in the chest or abdomen. The procedure for removing fluid from the chest is called thoracentesis. Removal of fluid from the abdomen is called paracentesis. Drugs may be given through a tube in the chest to prevent more fluid from accumulating. Radiation Therapy and surgery may also be helpful in relieving symptoms.
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