Balkinization  

Wednesday, October 03, 2007

"A Place of Inspiration"

Marty Lederman

That's Alberto Gonzales's description of the Department of Justice that would work tirelessly to produce these sorts of legal opinions. Having worked at OLC for many years, I genuinely can't even imagine what it would be like to come to work each day with a mandate to produce this sort of legal advice.

"[James] Comey told colleagues at the department that they would all be 'ashamed' when the world eventually learned of it." Were that it were so.

Between this and Jane Mayer's explosive article in August about the CIA black sites, I am increasingly confident that when the history of the Bush Administration is written, this systematic violation of statutory and treaty-based law concerning fundamental war crimes and other horrific offenses will be seen as the blackest mark in our nation's recent history -- not only because of what was done, but because the programs were routinely sanctioned, on an ongoing basis, by numerous esteemed professionals -- lawyers, doctors, psychologists and government officers -- without whose approval such a systematized torture regime could not be sustained.

Moreover, as I have argued many times in this space, there is no real justification for classifying the legal advice and the basic outlines of the CIA program (subject, of course, to protections for foreign sources who would be compromised).

What, then, will it take for Congress to have the courage finally to provide the thorough public accounting that is so desperately needed here -- and, perhaps more importantly, to pass laws that expressly and specifically prohibit identified techniques amounting to cruel treatment and torture; that prohibit secret, incommunicado CIA facilities; and that provide real legislative oversight so that this never happens again?

Comments:

Prof. Lederman:

I am increasingly confident that when the history of the Bush Administration is written, this systematic violation of statutory and treaty-based law concerning fundamental war crimes and other horrific offenses will be seen as the blackest mark in our nation's recent history -- not only because of what was done, but because the programs were routinely sanctioned, on an ongoing basis, by numerous esteemed professionals -- lawyers, doctors, psychologists and government officers -- without whose approval such a systematized torture regime could not be sustained.

But by no means a majority (or even necessarily a substantial fraction) of such professionals. All they needed to do was weed out those that objected to "the program", and that is precisely what they did. Sadly, in today's world you can always find enough people to sign their name onto such as the above ... or this and this. The problem is systemic and endemic. The only palliative measure possible is radical extirpation (followed by a full pathology report).

Cheers,
 

Professor Lederman:

I am increasingly confident that when the history of the Bush Administration is written, this systematic violation of statutory and treaty-based law concerning fundamental war crimes and other horrific offenses will be seen as the blackest mark in our nation's recent history...

What, then, will it take for Congress to have the courage finally to provide the thorough public accounting that is so desperately needed here -- and, perhaps more importantly, to pass laws that expressly and specifically prohibit identified techniques amounting to cruel treatment and torture[?]


I agree with the need for Congress to actually provide objective definitions of what is meant by "torture or cruel, inhuman and degrading treatment." Given that the current law does not provide such definitions, it is rather difficult to legitimately claim that the Bush Administration has committed "fundamental war crimes."
 

Given that the current law does not provide such definitions, it is rather difficult to legitimately claim that the Bush Administration has committed "fundamental war crimes."

Yes, that sort of defense worked so well for the Gestapo after the war, didn't it?
 

You may not like the definitions of cruel treatment and torture in the proposed legislation, but at least the proposed legislation has defintions which Article 3 lacks.
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Bart DePalma - September 23, 2006


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The NYT graphic in the post is a decent summary of the "objective" defintions of torture, cruel and inhuman as set out in US statute.
 

cboldt said...

You may not like the definitions of cruel treatment and torture in the proposed legislation, but at least the proposed legislation has defintions which Article 3 lacks. Bart DePalma - September 23, 2006

Unfortunately, after fencing over the application of the definition "severe pain" here and elsewhere for years with people of intelligence and I presume good faith, I can no longer conclude that this definition is adequately objective to apply in real life.

It appears that our divergent life experiences do not adequately inform a single common meaning for "severe pain." For example, many here have argued that the soreness and cramping from forcing the detainee to stand for long periods of time or in awkward positions constitutes "severe pain," while Mr. Rumsfeld and I do not because we experienced this discomfort as a normal part of our past or present employment without complaint.

This leads me to pose the question of whether it is at all possible to generically define terms like "torture." I am not at all sure it can be done.

I considered taking the path Yoo did by comparing it to known causes of paint such as a form of physical injury. However, if the fact finder has not suffered such a physical injury or the something similar to the interrogation technique under examination, he or she does not have a points of comparable reference. For example, suppose we define "severe pain" as that which you suffer from a broken bone. Prior to actually breaking my leg two years ago, I believed that such pain would be far worse than the pain which I actually suffered. Additionally, as I pointed out above, not all fact finders have apparently experienced comparable discomfort to that created by such interrogation techniques such as long time standing or awkward positions.

Therefore, I am compelled to agree with Professor Lederman's post that legislation in this area needs to define actual prohibited interrogation methods in order to become objectively enforceable and to lift the legal apprehension of our war fighters. The current regime is obviously unworkable.
 

Actually, it was working adequately until the Bush administration came along. What is true is that unless compelled the current Administration will not scruple to obey either the substance or the spirit of the legal system in the U.S. So I suppose they will have to be treated like the thugs they are.

Mr Rove et al have apparently learned from Mr Nixon's mistakes. Too bad it was the wrong lesson.
 

Bart writes: while Mr. Rumsfeld and I do not because we experienced this discomfort as a normal part of our past or present employment without complaint.

Was that during his three years as a flight instructor in the navy or during his time with the Nixon Administration? When did he confide this to you?
 

bitswapper said...

Bart writes: while Mr. Rumsfeld and I do not because we experienced this discomfort as a normal part of our past or present employment without complaint.

Was that during his three years as a flight instructor in the navy or during his time with the Nixon Administration? When did he confide this to you?


It was pretty widely reported that Rummy stands rather than sits at a desk all day and famously remarked, when reviewing the long time standing technique, that if he can stand more than 8 hours at a time, then so could a detainee.

As for myself, I stood in the turret of my Bradley for the better part of three days during the Persian Gulf War ground campaign. My feet were swollen and sore. Life is a b_tch, but that was not torture.

When I served in the 82d Airborne humping radios for the officers, I got to stand or sit in odd positions for hours on end with nearly 200 Lbs of gear draped all over my body. I was sore and got cramps. Life is a b_tch, but that was not torture.

Consequently, I could give less than a damn if we subject some terrorist who delights in murdering women and children to standing for long periods of time or in odd positions to wear down the SOB. Life is a b_tch, but that is not torture.

With all due and undue respect, some of you need to grow up and get real. War involves far worse than wearing down a terrorist with stress techniques.
 

Consequently, I could give less than a damn if we subject some terrorist who delights in murdering women and children to standing for long periods of time or in odd positions to wear down the SOB. Life is a b_tch, but that is not torture.

And of course, all those who were subjected to such torture were proven guilty of the crimes you mentioned before they were subjected to the treatment. And if they weren't, & were subjected to the torture until they made something up, or died? From previous threads, you never accept responsibility for such errors, or deem them unimportant to your larger goal. It just sucks to die in error.

And there is at least a slight difference between the experience of someone who self-subjects themselves to this treatment, and someone who has it forced upon them. Remember, that these treaments were the ones that the Russians felt would break our service people, and did in many cases (through their proxies or in our own tests on volunteers). Rumsfeld chose to stand for 8 hours a day. You were probably at least able to lean against the turret, or squat briefly, or take some other compensatory measure against your discomfort. Those subject to these tortures could not. Many were not likely guilty of terrorist activity, or like Taliban fighters, could arguably have been covered under GC regulations, but were subjected to such torture anyway, without recourse. Your arguments for the legality, ethicality, and morality of what happened continue to founder on these points.

And BTW, we all know that war is hell; but you still seem unduly fond of it, to paraphrase an expert, and overly dismissive of those who recognize that fact.
 

Fraud Guy said...

BD: Consequently, I could give less than a damn if we subject some terrorist who delights in murdering women and children to standing for long periods of time or in odd positions to wear down the SOB. Life is a b_tch, but that is not torture.

And of course, all those who were subjected to such torture were proven guilty of the crimes you mentioned before they were subjected to the treatment.


Once again, we are at WAR. This is NOT a criminal justice matter.

The laws of war did not require me to convict the Iraqi enemy of civilian crimes before I was allowed to kill them on the battlefield. It certainly does not require a conviction before they can be interrogated.

And if they weren't, & were subjected to the torture until they made something up, or died? From previous threads, you never accept responsibility for such errors, or deem them unimportant to your larger goal. It just sucks to die in error.

I accept ALL the results of my decisions, for good or bad.

Innocents are convicted and lose their freedom and lives in our criminal justice system. This is not a reason to throw out our criminal justice system. Rather, it is an argument for doing our best to ensure we identify the guilty.

Innocents die or are captured and interrogated in the fog of war. That does not mean that we refuse to wage war when the enemy hides behind civilians or decline to capture and interrogate anyone in civilian clothing. Rather, it is an argument for doing our best to ensure we identify the enemy.

And BTW, we all know that war is hell

Based on the posts here, I really doubt that most of you have the slightest idea what war is all about.

...but you still seem unduly fond of it...

War sucks. Killing is not fun. I have the blood of perhaps several dozen Iraqis on my hands who I killed or ordered killed and I still have nightmares about it. I hope God forgives me, but I would do it again because it needed to be done.

Likewise, I would be willing to go to war again aganst al Qaeda if they would take this middle aged vet because it needs to be done and frankly I was good at my job. I am willing to accept the fact that innocents may die or be interrogated in this war. However, if we want to avoid repeats of the massacres at WTC 93, Khobar, the Kenyan Embassy, the USS Cole and 9/11, then we have to take the enemy who perpetrated these massacres seriously and do what it takes to take them out - period, end of story.
 

Likewise, I would be willing to go to war again aganst al Qaeda if they would take this middle aged vet

There are people much older than you in Iraq. I'm sure they would take you back in a heartbeat. It's quite odd that you haven't even bothered to look into it....
 

What, then, will it take for Congress to have the courage finally to provide the thorough public accounting that is so desperately needed here ....?

A new Congress. A new media. A new Democratic Party. A new electorate.
 

This leads me to pose the question of whether it is at all possible to generically define terms like "torture." I am not at all sure it can be done.

Bart, you are simply out of your element here. I have litigated torture cases. And I can assure you that there is an entire body of law dedicated to the concept, and that both courts and organs of international law have not had that many problems determining what did and didn't qualify. It has certainly proven less difficult to define than many familiar common law concepts, such as "intent", "date of marital separation", "possession", and "consent".

When John Yoo and Jay Bybee imported a definition from an emergency room health care law (which actually had nothing to do with torture-- it was defining what constituted an emergency) to define torture, they were either committing malpractice (if they were unaware of the actual body of law defining torture) or were lying through their teeth (if they were aware of it and were ignoring it). Conservatives have spent this whole debate pretending that there is some uniquely difficult problem defining "torture", when there isn't.

Here are a smattering of the many areas of the law that Bybee and Yoo could have drawn on, and that you could consult if you actually wanted to learn about what constitutes "torture" rather than continuing to pretend that it has no definition:

1. The UN Convention Against Torture, and the authorities interpreting it.

2. The decisions of international war crimes tribunals in torture cases.

3. The decisions of American courts interpreting statutes prohibiting torture (many of which use the same or a similar definition to that used in the Convention Against Torture).

4. The decisions of American courts interpreting 28 U.S.C. Section 1350 (which incorporates the Convention Against Torture definition).

5. The decisions of American courts interpreting the Torture Victim Protection Act (which contains a definition identical to the definition in the Convention Against Torture).

6. The decisions of US courts imposing sentencing enhancements based on torture.

You see, Bart, in actual courts, where actual law is made on this subject, workable definitions of torture have been consistently applied for years. And since many of these cases are criminal cases, these definitions have survived the heightened vagueness scrutiny required by the Fifth Amendment.

So don't give us these conservative BS talking points about how hard it is to know what torture is. That's just a way of avoiding the real issues here.
 

Thank you, Bart:

The laws of war did not require me to convict the Iraqi enemy of civilian crimes before I was allowed to kill them on the battlefield. It certainly does not require a conviction before they can be interrogated.

Ah, you finally admit to the laws of war (with parts quaintly known as the Geneva Conventions).

First, another humongous strawman. I agree that the exigencies of the battlefield may prevent capture of someone. I did not ask you to restrain someone while you were under fire, in a stress position.

However, many captures of purported terrorists occurred far from the battlefield, and far from Iraq and Afghanistan; in fact, you may have heard of a few rendition cases. In that case, the established civil procedures should have had highest priority, at least until the status of the person detained is legally determined (near a war zone, the established military procedure may arguably be used, but the deciding between either procedure is covered under GC). However, under GC, it appears the capturing power is still supposed to treat the captives under its requirements, and under its own civil or military code (as if the detainee was a member of its own military).

And as to reupping; I knew the sister of an intelligence specialist who was recalled to reserve duty during the invasion prep when he was in his mid-50's. Blackwater is hiring, also, and from reports they may need some attorneys soon. Good luck on your career change.
 

Dilan said...

This leads me to pose the question of whether it is at all possible to generically define terms like "torture." I am not at all sure it can be done.

Bart, you are simply out of your element here. I have litigated torture cases. And I can assure you that there is an entire body of law dedicated to the concept, and that both courts and organs of international law have not had that many problems determining what did and didn't qualify.


OK, please post the agreed upon definition of "torture" developed by the judiciary in the absence of legislative guidance. You cannot because there is not one. At best, you will be able to offer something along the lines of Potter Stewart's crack about pornography that: "I know it when I see it."

I am sorry, but you cannot have a legitimate rule of law absent the rules. If the judges are substituting their own subjective personal policy opinions of what constitutes torture, then we have a government of men and not of laws.
 

Bart, your testimony betrays you. The laws of war do prevent you from firing, or convicting civilians to death without trail. And the laws of war do not permit you to classify whoever you damn well please as enemy combatants. What meaning would the laws of war have if any man, woman or child could be killed, tortured or inhumanely treated on the flimsiest of suspsicion or evidence? The most favorable interpretation of your position is that you are foolish enough to believe everyone accused of insurgency in Iraq is guilty of the same. At worst, you just don't give a damn about all the innocent in prison.
 

Between this and Jane Mayer's explosive article in August about the CIA black sites, I am increasingly confident that when the history of the Bush Administration is written, this systematic violation of statutory and treaty-based law concerning fundamental war crimes and other horrific offenses will be seen as the blackest mark in our nation's recent history

I don't suppose you're giving odds and taking wagers?
 

OK, please post the agreed upon definition of "torture" developed by the judiciary in the absence of legislative guidance.

What do you mean "in the absence of legislative guidance"? What do you think the Convention Against Torture is? What do you think the Torture Victim Protection Act is? What do you think the myriad of state and federal statutes defining torture as a crime and as a sentencing enhancement are?

Indeed, torture has an accepted definition under both US and international law and has had one since at least the Filartiga v. Pena-Irala decision 27 years ago: the intentional infliction of severe mental or physical suffering for any purpose, other than as part of a lawful penal sanction.

So that's the legislative guidance. You will find close variations of this in international treaties, federal statutes, and state laws.

Now, what do judges (and juries, by the way) do? They determine what actions fit within that definition. Just like they do with any other statutory definition. Just like they do with rape: "the sexual penetration of another without consent by force or threat of force". Now, does drugging the woman with rohypnol or GHB and then having sex with her constitute rape? Well, that's what courts decide. (Indeed, many common law offenses are decided by judges without any legislative guidance whatsoever. Do you think that is illegitimate too?)

So we have a body of law determining what constitutes torture, e.g.:

Battering a person with a hammer (http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/2006/10/24/BABADIGEST3.DTL&feed=rss.bayarea)

Stripping a person nude and tying her to a post (see Abebe-Jira v. Negewo, 11th Circuit, 1995)

Sustained beating, electric shocks, tying people up, and long-term stress positions (see Simpson v. Lybia, D.C. Circuit, 2003)

Brutal rape, forced impregnation, and forced prostitution (Kadic v. Karadzic, 2nd Circuit, 1995)

In contrast, using dangerous herbicides does not constitute torture. (Arias v. Dyncorp, D.C. Circuit, 2007).

I should add at this point that I really think you are arguing in bad faith. You seem to want a code of permitted and prohibited interrogation practices. There's a reason the law of torture doesn't work that way, and it is the same reason that the law of rape doesn't consist of a list of specifically prohibited sexual activities and the fourth amendment doesn't specifically list what searches are unreasonable: This invites circumvention.

The point of all the international and domestic prohibitions of torture is that this is bad conduct, however it is carried out. One should never, in other words, deliberately inflict severe mental or physical suffering on another person. If we make a specific list, and take the power away from judges to interpret the definition, governments and officials and other bad actors will use that as an excuse to use any method they can think of that is not specifically prohibited.

Instead, we enshrine the principle, and let courts apply the definition.

If you don't like that, what you are really arguing is that there is no basis for lawmakers to make general pronouncements of categorically illegal activities, while allowing judges and juries to apply those laws to specific cases. You are simply opposed to the entire western tradition of lawmaking and the system of common law courts.

I don't believe this is really true. I think instead you have just argued yourself into a corner because you don't want to admit that torture isn't any more difficult to define and proscribe than any other illegal activity.
 

This comment has been removed by the author.
 

Dilan,

Thank you,

Fraud Guy
 

dilan said...

BD: OK, please post the agreed upon definition of "torture" developed by the judiciary in the absence of legislative guidance.

What do you mean "in the absence of legislative guidance"? What do you think the Convention Against Torture is? What do you think the Torture Victim Protection Act is? What do you think the myriad of state and federal statutes defining torture as a crime and as a sentencing enhancement are?


An utter absence of guidance.

I notice that you do not quote an objective definition of torture from any of your sources. That is because there is none and, as I have pointed out, no one here including myself can come up with one on their own.

I am hardly alone in this breathtakingly obvious conclusion. The lack of guidance and resulting uncertainty is a main theme of the NYT article which started this thread and Jack Goldsmith's book.

Indeed, torture has an accepted definition under both US and international law and has had one since at least the Filartiga v. Pena-Irala decision 27 years ago: the intentional infliction of severe mental or physical suffering for any purpose, other than as part of a lawful penal sanction.

This is not an objective definition because every single person here would draw the line of severe pain at a different place because we all have different life experiences which inform our grading of pain. The debates here and in the government on where to draw the line is pretty obvious proof that there is no objective definition.

Now, what do judges (and juries, by the way) do? They determine what actions fit within that definition. Just like they do with any other statutory definition. Just like they do with rape: "the sexual penetration of another without consent by force or threat of force".

This is a perfect contrast to the definition of torture and further proof of my point. Each and every element of rape has an objective meaning which is defined in the jury instructions or by a commonly held meaning.

The fact that this or any other definition of a crime does not adequately define another bad act that we think should be a crime does not mean that we should stop providing definitions for criminal acts. Rather, it means that the legislature needs to create another definition to cover the new bad act which it thinks should be criminal.

Indeed, many common law offenses are decided by judges without any legislative guidance whatsoever. Do you think that is illegitimate too?

Most certainly. There are no federal common law offenses and very few left in the states. Indeed, it has been long held that the Federal courts are not empowered to create common law.

So we have a body of law determining what constitutes torture, e.g.

None of which shares a common objective definition. Instead, each judge is making his or her own policy preference.

I should add at this point that I really think you are arguing in bad faith. You seem to want a code of permitted and prohibited interrogation practices. There's a reason the law of torture doesn't work that way...This invites circumvention.

All law invites circumvention. Many a wag has noted that this is what lawyers are for. Indeed, Jack Goldmith admitted that most of his job as OLC was to guide the President around legal obstacles so he could get about his duties of defending the country.

However, when criminal law is defined after the fact by courts, people are subjected to criminal liability for acts which were not crimes when they were committed. Even this former prosecutor can see that is fundamentally wrong and a violation of due process.

This is why the United States has almost completely abandoned common law crimes and sought to define criminal behavior as precisely as possible in statute.
 

This is a perfect contrast to the definition of torture and further proof of my point. Each and every element of rape has an objective meaning which is defined in the jury instructions or by a commonly held meaning.

Really Bart? So does "force or threat of force" include surreptitiously drugging the victim or not? I know how the courts have generally answered this one, but the idea that the definition is crystal clear and leaves no room for interpretations is just wrong.

And how about the statutes I listed in the other thread? Is "defrauding the government" so clear that there need be no judicial interpretation? "Material support" to a foreign terrorist organization? "Misbehavior" in a courtroom?

Yet all of these statutes have survived vagueness challenges. You see, Bart, what you are arguing is simply not the law-- if you really believe it (and I don't think you do-- you just don't want to admit you were wrong at this point), it is the fantasy of a conservative who doesn't like judges and thinks that their role (at least in federal criminal cases) can be reduced to mechanistically applying the clear and plain language of statutes.

Most certainly. There are no federal common law offenses and very few left in the states.

Wow, Bart. You are basically saying that the Anglo-American common law tradition, which has governed western societies for at least 800 years, should be junked. Even if you were right on the merits (which you are not), I would still note that it would be absolutely absurd to interpret a Constitution written by people who clearly intended to import that tradition into the newly-formed United States as prohibiting it. (Of course, it would be one more piece of evidence that conservatives can be the biggest judicial activists of them all.)

However, when criminal law is defined after the fact by courts, people are subjected to criminal liability for acts which were not crimes when they were committed.

Bart, they were crimes. The rule you are arguing for simply doesn't exist. The due process vagueness test simply requires that a person of common intelligence can understand the language of the statute. That's it. And this has been established law at least 35 years and perhaps quite a bit earlier than that.

In your hypothesized world, the GHB rapist could never be prosecuted unless the state passed a specific statute prohibiting the surreptitious use of a pharmaceutical to obtain consent. In your hypothesized world, judges could never punish a contempt of court, because the statute doesn't enumerate what kind of "misbehavior" constitutes contempt. In your hypothesized world, there could never be a treason prosecution-- what the heck does "adhering to [the United States'] enemies, giving them aid and comfort" mean, anyway?

I invite any person reading this debate to go on findlaw.com and look at some of the criminal statutes passed by Congress, in Title 18 of the US Code. They will see numerous statutes that are far more general than the torture statute. And yet a quick search of caselaw will reveal that their constitutionality has been upheld against vagueness challenges.

Again, the only reason we are having this discussion is because conservatives don't want the torture definition applied to Bush's conduct and therefore have to pretend that torture is this impossible to define term rather than a concept that legislatures, judges, and state-parties to treaties have worked with for over 60 years. And that argument, by the way, is one that the Bush Administration's own lawyers would blithely dismiss if it were made by a defendant challenging a sentencing enhancement for torture in a criminal prosecution.
 

Bart writes:
It was pretty widely reported that Rummy stands rather than sits at a desk all day and famously remarked, when reviewing the long time standing technique, that if he can stand more than 8 hours at a time, then so could a detainee.


That doesn't make him an authority.

As for myself, I stood in the turret of my Bradley for the better part of three days during the Persian Gulf War ground campaign. My feet were swollen and sore. Life is a b_tch, but that was not torture.

That doesn't make you an authority either. Nor does it give any weight to your denial.

With all due and undue respect, some of you need to grow up and get real.

Childish insults don't comprise any kind of merit, either.
 

Dilan said...

This is a perfect contrast to the definition of torture and further proof of my point. Each and every element of rape has an objective meaning which is defined in the jury instructions or by a commonly held meaning.

Really Bart? So does "force or threat of force" include surreptitiously drugging the victim or not?


The fact that you have to ask the question means that the common meaning of "force" does not readily apply to drugs. To remedy this problem, many states simply rewrote their rape laws to clearly state "force or drugs." I am likewise suggesting that Congress needs to rewrite its torture statute to become much more specific.

In any case, you are changing the subject at hand - does the definition "severe pain" have a common meaning which a jury could objectively apply to determine if a defendant tortured. You are essentially admitting that it does not and a court will have to determine after the fact whether an act constitutes "torture." That is the problem.

BD: Most certainly. There are no federal common law offenses and very few left in the states.

Wow, Bart. You are basically saying that the Anglo-American common law tradition, which has governed western societies for at least 800 years, should be junked.


So far as criminal law goes, I believe that has been the vast majority position for decades now.

Indeed, many states have begun to reign in the common law in the civil system by enacting statutes which define what are and are not duties in such areas a premises and construction liability.

The problem with the common law is the same in both criminal and civil proceedings. Whenever a court comes up with a new theory of liability after the act in question, they are in fact imposing an ex post facto law. The Courts have generally limited the constitutional prohibition on ex post facto laws to criminal laws with punishment, while allowing ex post facto procedural or "remedial" laws involving money and property. This is why common law crimes have largely been abolished.

If I had my druthers, I would also abolish civil common law as well and replace it with a statutory establishment of civil duties. The unfairness of ex post facto liability in civil matters may be less than criminal, but it is still fundamentally unfair.
 

Dilan: You have offered an excellent discussion of ideas that often occur to me when reading "conservative BS talking points." As a former prosecutor and federal public defender with twenty years of trial experience, I too find the pettifoggery of torture apologists intolerable. From the hokey jurisdictional arguments that attempted to deprive US courts of authority over the lives of people confined without charges by the US military, to the insane grants of immunity to mercenaries who kill civilians with impunity, these corrupt lawyers have aided an administration fixated on securing absolute power to justify international and domestic outrages. War crimes charges would be too good for them. The fate of Il Duce would be far more just.
 

In any case, you are changing the subject at hand - does the definition "severe pain" have a common meaning which a jury could objectively apply to determine if a defendant tortured. You are essentially admitting that it does not and a court will have to determine after the fact whether an act constitutes "torture." That is the problem.

That's no problem at all. Trier of fact determines whether conduct constitutes torture. If trier of fact misapplies law, trial and appellate courts correct it.

This is what happens in numerous criminal cases.

In any event, I think you have effectively conceded my point that this is how the law works right now. You may disagree with it, and would be very aggressive in allowing ex post facto or vagueness challenges to common law rules or statutes that do not spell out exactly what is precluded and permitted. Personally, I think this would be disasterous, for any number of reasons (e.g., it would usurp the role of the jury in deciding issues of reasonable care; it is impossible for legislatures to pass specific rules that would govern all of the potential circumstances that arise in litigation; it would encourage circumvention of the rules, etc.).

But the way the law works right now is that Congress has passed many general criminal statutes, and juries and judges interpret them to apply to specific situations. So long as the language of the statute is comprehensible to an ordinary person, there is no vagueness problem.
 

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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:
abdominal pain
ascites, or an abnormal buildup of fluid in the abdomen
a mass in the abdomen
problems with bowel function
weight loss
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
pleural effusion
pulmonary emboli, or blood clots in the arteries of the lungs
severe ascites
A
mesothelioma does not usually spread to the bone, brain, or adrenal glands. Pleural tumors are usually found only on one side of the lungs
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. 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
Incidence
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.
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.
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
mesotheliomaExposure to
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.
Commercial
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.
Although
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
How is
mesotheliomadiagnosed?
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.
How is
mesotheliomatreated?
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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