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Terrorism and National Security Issues
Three Muslim residents of California filed a lawsuit against U.S. government defendants and FBI agent defendants, and sought class action certification. They claimed that the FBI paid a confidential informant to conduct a covert surveillance program that gathered information about Muslims based solely on their religious identity. They argued that the investigation involved unlawful searches and anti-Muslim discrimination, in violation of eleven constitutional and statutory causes of action. A federal appeals court ruled that some of the claims dismissed on state secrets grounds should not have been dismissed outright. Instead, the trial court should have reviewed any state secrets evidence necessary for a determination of whether the alleged surveillance was unlawful following the secrecy protective procedure in the Foreign Intelligence Surveillance Act (FISA). The court also held that the Fourth Amendment injunctive relief claim against the official-capacity defendants should not have been dismissed, because expungement relief was available under the Constitution to remedy the alleged constitutional violations. Fazaga v. FBI, #12-56867, 2019 U.S. App. Lexis 6028 (9th Cir.).
Two U.S. citizens asserted that they had missed flights and been humiliated at airports after they were placed on the federal government’s “Selectee List,” which designates them for enhanced screening at the airport. That list is a subset of the government’s Terrorist Screening Database (TSDB). The Terrorist Screening Center (TSC) decides whether to accept the designation of a person by the FBI or the National Counterterrorism Center to the TSDB or the Selectee List and decides whether to remove a name after it receives a redress request. Both plaintiffs claimed that they had tried to challenge their inclusion on the list but had only received generalized responses that neither confirmed nor denied their inclusion. Their Fifth Amendment and unlawful agency action claims were dismissed. A federal appeals court upheld this result. The plaintiffs failed to show which protected interest was violated. While they may have been inconvenienced by the extra security precautions, this did not violate their constitutional rights. They had not been entirely prevented from flying or from traveling by other methods. Beydoun v. Sessions, #16-406, 2017 U.S. App. Lexis 17575, 2017 Fed.App. 0214P (6th Cir.)
A trial court ruled that the federal
government's "bulk data program" collection was an unlawful search
under the Fourth Amendment. The program, started pursuant to the USA PATRIOT
Act, under which Sec. 215 empowers the FBI to request, and the Foreign
Intelligence Surveillance Court to enter, orders “requiring the production of
any tangible things (including books, records, papers, documents, and other
items) for an investigation . . . to protect against international terrorism.”
The trial court enjoined the government from collecting the plaintiffs' call
records, but the order was stayed pending appeal. The injunction was overturned
on appeal, Two separate opinions of two of the appeals panel judges determined
that the plaintiffs failed to show that they had a substantial likelihood of
prevailing on the merits. One judge found that the plaintiffs barely met the
requirements for standing by showing that it was possible, but not
substantially likely, that their own call records were collected as part of the
bulk telephony metadata program, but they had not met the higher burden of
proof required for a preliminary injunction. The second judge's opinion found
that the plaintiffs had failed to demonstrate a "substantial
likelihood" that the government was collecting data from Verizon Wireless,
the phone company they used, or that they suffered any "cognizable
injury." Klayman v. Obama, #14-5004, 800 F.3d 559 (D.C. Cir. 2015).
Muslim plaintiffs
claimed that the New York City Police Department, since January of 2002, had
carried out a secret program monitoring the lives of Muslims, as well as their
businesses, houses of worship, organizations and schools both in New York and
surrounding states such as New Jersey solely because they were Muslim. The
program allegedly included the use of remote controlled surveillance cameras
aimed at mosques and the sending of undercover officers into mosques, student
organizations, businesses, and neighborhoods believed to be heavily Muslim. The
plaintiffs argued that this falsely stigmatized Muslims as criminals who should
be pervasively surveilled. Overturning a trial court dismissal of the lawsuit
for lack of standing and failure to state a claim, a federal appeals court held
that the allegations “tell a story in which there is standing to complain and
which present constitutional concerns that must be addressed and, if true,
redressed.” The court compared the alleged surveillance program to the
situations faced by Japanese-Americans during World War II, Jewish-Americans
during the Red Scare era, and African-Americans during the civil rights era.
Claims in the case involved alleged violations of religious liberty under the
First Amendment and equal protection violations based on intentional
discrimination against a protected class. The court stated that the allegations
raised a presumption of unconstitutionality that the city had an obligation to
rebut. The plaintiffs' First Amendment religious freedom claims could also go
forward. Hassan v. City of New York, #14-1688, 2015 U.S. App. Lexis 17776 (3rd
Cir.).
The plaintiff, a U.S. citizen, sued the FBI for
violations of constitutional rights under Bivens v. Six Unknown Named Agents of
Fed. Bureau of Narcotics, claiming that FBI agents detained, interrogated, and
tortured him over the course of four months in three countries in Africa.
Upholding the dismissal of the lawsuit, the federal appeals court stated that
when the actions occurred during a terrorism investigation, "special
factors" required hesitation in allowing a Bivens lawsuit for money
damages. Bivens actions are usually not favored in cases involving the
military, national security, or intelligence gathering. Further, the U.S.
Supreme Court had never “created or even favorably mentioned a nonstatutory
right of action for damages on account of conduct that occurred outside the
borders of the United States.” The issue of remedies involving matters of
foreign policy and national security are usually left to the political branches
of government. Meshal v. Higgenbotham, #14-5194, 2015 U.S. App. Lexis 18453
(D.C. Cir.).
A federal appeals court held that a telephone
metadata program under which the National Security Agency (NSA) collected in
bulk "on an ongoing daily basis" the metadata associated with
numerous phone calls made by and to Americans, was not authorized by Sec. 215
of the PATRIOT Act. The appeals court did not consider the constitutionality of
the program or rule that a preliminary injunction was required, leaving it for
the trial court on remand to consider the propriety of preliminary relief. The
trial court had denied relef, holding that the plaintiffs were precluded from
bringing suit against the federal government about this program, but there was
a right of action under the Administrative Procedure Act, 5 U.S.C. Sec. 702.
ACLU v. Clapper, #14-42, 2015 U.S. App. Lexis 7531 (2nd Cir.).
A federal court ruled that the U.S. government's
"no-fly" list, barring certain named people from flying as part of
efforts to combat terrorism, violated the constitutional rights of a number of
people on the list by depriving them of their constitutional right to travel
while failing to provide them with an adequate means to challenge their
inclusion on the list. There were 13 plaintiffs, including four military
veterans. Latif v. Holder, #3:10-cv-00750, 2014 U.S. Dist. Lexis 85450 (D.
Ore.).
A federal appeals court has ordered the
release of a redacted copy of a secret Justice Department memo providing a
legal argument justifying a 2011 drone attack that killed a U.S. male citizen
suspected of being an al Qaeda leader. The court found that there had been a
waiver of secrecy and privilege under Exemption 5 of the Freedom of Information
Act as to the content of the legal analysis by the Office
of Legal Counsel (OLC)-DOD memorandum. This was the case because senior government
officials assured the public that such targeted killings of U.S. citizens by
drones abroad were lawful and that the OLC advice established the legal
boundaries within which the government operated. The government had already
made public a detailed analysis of nearly all the legal reasoning contained in
the memo. There was no longer any logical or plausible way to argue that the
disclosure of the redacted memo risked disclosing any military plans,
intelligent activities, sources and methods, or foreign relations details. Some
other documents were properly withheld because they were
"pre-decisional" and informal, and some others were ordered to be
submitted to the court for an in camera examination. New York Times Company v.
U.S. Dept. of Justice, #13-422, 2014 U.S. App. Lexis 11733 (2nd Cir.).
Six Muslim individuals and a number of
Muslim-owned businesses, mosques, and a student organization claimed that the
New York City Police Department's surveillance of the Muslim community in New
Jersey following the attacks of September 11, 2001 violated the First and
Fourteenth Amendment by targeting Muslims solely on the basis of their
religion. The federal trial court dismissed the lawsuit. “The more likely
explanation for the surveillance was a desire to locate budding terrorist
conspiracies. The most obvious reason for so concluding is that surveillance of
the Muslim community began just after the attacks of September 11, 2001. The
police could not have monitored New Jersey for Muslim terrorist activities
without monitoring the Muslim community itself.” The court also stated that,
“Nowhere in the complaint do plaintiffs allege that they suffered harm prior to
the unauthorized release of the documents by the Associated Press. This
confirms that plaintiffs’ alleged injuries flow from the Associated Press’s
unauthorized disclosure of the documents. The harms are not ‘fairly traceable’
to any act of surveillance.” An appeal in the case is expected. Hassan v. City
of New York, #2-12-3401, 2014 U.S. Dist. Lexis 20887 (D.N.J.).
A federal district court ruled that the Google
search engine company must provide private user data to the FBI pursuant to 17
out of 19 properly issued National Security Letters (NSLs), despite the fact
that there was no judicially issued warrant for the information. The judge
requested more information on the remaining two NSLs. NSLs allow FBI officials
to send secret requests for "name, address, length of service," and
other account information to online companies, banks, and other businesses as
long as there is relevance to a national security investigation. In Re: National
Security Letters, #C-13-80063, U.S. Dist. Ct. (N.D. Cal. May 28, 2013).
A U.S. citizen who had been confined as an enemy
combatant and his mother filed a federal civil rights lawsuit against a former
deputy assistant U.S. attorney general, asserting claims for unlawful detention
and abusive interrogation, including an assertion that he had been tortured.
The defendant had essentially written legal memoranda presenting the case for
detaining terrorism suspects, following the September 11, 2001 attacks, as
enemy combatants, and using interrogation techniques considered controversial.
The defendant was entitled to qualified immunity, as, at the time of the defendant's
conduct, it was not clearly established that a suspected terrorist, who was not
a criminal defendant or convicted prisoner, was entitled to the same
constitutional rights as they had while in military custody by Presidential
order. It was also not clearly established, at the time, that the interrogation
techniques allegedly involved rose to the level of illegal torture. Padilla v.
Yoo, #09-16478, 2012 U.S. App. Lexis 8934 (9th Cir.).
A federal appeals court reversed a trial court
decision denying a Malaysian professor the ability to go forward on her lawsuit
seeking to have her name removed from a U.S. government "no fly" list
and other terrorist watchlists. The court found that the plaintiff had standing
to assert her claims challenging her name's placement on the lists, and had
sufficient voluntary connections to the U.S. to assert First and Fifth
Amendment claims although she lives outside the country, based on her prior
studies here, and her previous intention to return to this country after presenting
her research at a conference abroad. Ibrahim v. Dep't of Homeland Security,
#10-15873, 2012 U.S. App. Lexis 2457 (9th Cir.).
A federal appeals court ruled that
residential telephone customers could proceed with their claims that the
federal government, with the assistance of major telecommunications companies
"engaged in widespread warrantless eavesdropping in the United States
following the September 11, 2001, attacks," constituting a
"communications dragnet of ordinary American citizens." The court
found that the plaintiffs had made detailed allegations and claims of harm,
that the claims were not barred by the "political question" doctrine,
and that the fact that the claim of illegal wiretapping arose in the context of
national security issues did not impose on the plaintiffs any heightened
scrutiny requirement in terms of the details they had to provide in their
complaint. Claim were asserted concerning alleged violations of the First
Amendment right of association, violation of the Fourth Amendment, and
violation of federal wiretapping and privacy laws. Jewel v. National Security
Agency, #10-15616, 2011 U.S. App. Lexis 25951 (9th Cir.).
The U.S. Supreme Court held that former Attorney
General Ashcroft was entitled to qualified immunity in a lawsuit by a man
detained after the events of 9/11/2001 under a federal material witness
statute. The plaintiff claimed that the government had a policy of using this
statute to detain innocent persons suspected of terrorism without charges.
The Court held that the objectively reasonable arrest and detention of a
material witness pursuant to a validly obtained warrant cannot be challenged as
unconstitutional on the basis of allegations that the arresting authority had
an improper motive. Ashcroft did not violate clearly established law and thus
is entitled to qualified immunity because, at the time of the arrest, not a
single judicial opinion had held that pretext could render an objectively
reasonable arrest pursuant to a material-witness warrant unconstitutional.
Ashcroft v. al-Kidd, #10-98, 2011 U.S. Lexis 4021.
By 6-3, the U.S. Supreme Court rejected a First
Amendment challenge to a federal statute which criminalizes providing
"material aid" to designated foreign terrorist organizations even when
the aid provided is purportedly aimed at facilitating training for peacefully
resolving conflicts or asserting human rights claims. “At bottom,” Chief
Justice Roberts wrote for the majority, “plaintiffs simply disagree with the
considered judgment of Congress and the executive that providing material
support to a designated foreign terrorist organization — even seemingly benign
support — bolsters the terrorist activities of that organization.” Holder v.
Humanitarian Law Project, #08-1498, 2010 U.S. Lexis 5252.
A Pakistani Muslim was arrested on
suspicion of terrorist activity by federal agents following the September 11,
2001 terrorist attack and detained in restrictive conditions. He filed a
federal civil rights action against a number of federal officials, including
the Attorney General and the F.B.I, director, claiming that he had been
unjustly labeled a person of "high interest" because of his race,
religion, or national origin. The lawsuit also objected to the arrest and
detention of thousands of Arab Muslim men during the September 11th
investigation, as well as to purportedly overly harsh conditions of
confinement. The Court overturned the denial of the government's motion to
dismiss the lawsuit, finding that there were insufficient facts pled to show
purposeful and unlawful discrimination. There was no showing that the policy
under which the plaintiff was detained was the product of discrimination. The
Court noted that because the September 11th terrorist attacks were carried out
by Arab Muslims, "it is not surprising" that a legitimate policy
directing law enforcement to arrest and detain individuals because of their
suspected link to the attacks would produce a disparate, incidental impact on
Arab Muslims, even though the policy's purpose was to target neither Arabs nor
Muslims. The Court stated that the appeals court below should determine whether
the plaintiff should be allowed to amend his complaint. Ashcroft v. Iqbal, No.
07-1015, 2009 U.S. Lexis 3472.
A man allegedly subjected to illegal wiretapping,
physical surveillance, and placement on terrorist watch lists after telling an
airline that it should screen everything to avoid the placement of bombs on
airplanes could pursue Fourth Amendment, First Amendment, and privacy claims,
as he sufficiently alleged that he suffered harm from these actions.
Additionally, while 49 U.S.C. Sec. 46110(a) denied the court jurisdiction over
claims concerning the Transportation Security Administration watch lists, it
did not bar claims concerning the plaintiff's possible placement on other watch
lists. Tooley v. Napolitano, No. 07-5080, 2009 U.S. App. Lexis 3252 (D.C.
Cir.).
Two long time friends of Arab ethnicity flying
from San Diego to New York claimed that they were improperly seized after they
got off the plane and confronted with shotguns and police dogs, after which
they were placed in police station cells for four hours and questioned about
alleged terrorist surveillance actions on the plane. No evidence of wrongdoing
on their part was found, they stated. In a federal civil rights and Federal
Tort Claims Act lawsuit against a police detective, an FBI agent, and two
counter-terrorism agents, the court ruled that the plaintiffs' Arab ethnic
origin could not be used, under the Fourth Amendment, as a factor in deciding
whether their detention was justified, and that race can not be used to show
criminal propensities. Farag v. U.S., Case No. 05-CV-3919, 2008 U.S. Dist.
Lexis 95331 (E.D.N.Y.).
A Malaysian Muslim in the U.S. on a student visa
sought injunctive relief to remove her name from a "No-Fly" list.
When she attempted to fly from California to Malaysia, the airline allegedly
found her name on the government's No-Fly list, and a federal employee told
local police to prevent her from flying and to detain her for interrogation, as
well as to call the FBI. She was handcuffed and release after two hours. The
next day, she was allowed to fly, but only after being subjected to
"enhanced" searches. The court found that because placing the
plaintiff's name on the No-Fly list was a result of an FBI order, and the
FBI is not an agency named in 49 U.S.C. Sec. 46110 (requiring challenges
to Transportation Security Administration orders, including the no-fly list, be
filed in a federal appeals court, limiting the right to trial by jury), the
trial court had jurisdiction to review the order to determine whether the
inclusion of her name on the list violated her civil rights. While the
Transportation Security Administration maintains the No-Fly list, according to
the court, its compilation is handled by a branch of the FBI, the Terrorist
Screening Center, which is not named in the statute as an agency whose orders
have to be challenged only through proceedings in a federal appeals court.
Other claims were dismissed, including a claim under 42 U.S.C. Sec. 1983, since
none of the defendants acted under color of state law. Ibrahim v. Dept. of
Homeland Security, No. 06-16727, 538 F.3d 1250 (9th Cir. 2008).
The plaintiff, a U.S. citizen, went to Iraq to
work on a documentary film, and was arrested and then detained in a U.S.
military camp after washing machine timers were found in his taxi. Such timers,
according to the court, are often used in explosive devices. He was allegedly
held for 48 days before he was provided with a hearing before a military
officers' panel, following which an investigation cleared him of criminal
conduct. He was then released six days later. He sued two generals, a number of
other unnamed defendants, and the former Secretary of Defense, claiming that
his Fourth and Fifth Amendment rights were violated by these actions. The
federal trial court ruled that the plaintiff was protected by the provisions of
the Bill of Rights while overseas, but that the defendants could not be held
liable. They were entitled to immunity as the prior clearly established case
law concerning the right to a timely probable cause hearing concerned detainees
on "non-hostile U.S. territory" rather than overseas. There was also
no violation of his right to due process, since he received prompt notice of
the charge against him. In the setting of a battlefield, the court commented,
the government has a strong interest in providing for the safety of military
personnel, and this took priority over the holding of a probable cause hearing
under the circumstances. The lawsuit was dismissed. Kar v. Donald Rumsfeld,
Civil Action No. 07-0984, 2008 U.S. Dist. Lexis 73974 (D.D.C.).
A Malaysian Muslim student in the U.S.
sought injunctive relief to remove her name from the Defendant's "No-Fly
List," and also sought to challenge policies and procedures implementing
that list. The plaintiff attempted to fly from San Francisco to Malaysia, but
was barred from doing so when the airline found her name on the "No-Fly
List" provided by the federal government. A federal employee allegedly
told local police not only to prevent her from flying, but also to detain her
for further questioning by the FBI. She was handcuffed and taken to a police
station, and released two hours later. She was allowed to fly the next day, but
only following detailed searches. A federal trial court dismissed her claims
against the federal government and a federal employee, as well as those against
an airline and an airline employee. A federal appeals court ruled that 49
U.S.C. Sec. 46110 stripped the trial court of jurisdiction over any claim the
student might otherwise have had concerning government policies and procedures
involved in the implementation of the "No-Fly List." Any
claims under 42 U.S.C. Sec. 1983 were properly rejected because none of the
defendants acted under color of state law. Individual capacity claims against
the federal employee for violation of civil rights and state law claims,
however, could go forward. Ibrahim v. Dept. of Homeland Security, No. 06-16727,
2008 U.S. App. Lexis 17572 (9th Cir.).
New York appellate panel affirms a jury verdict
that the Port Authority was more than two-thirds responsible for the 1993
terrorist bombing of the World Trade Center that killed six persons and injured
more than a thousand. Nash v. Port Auth. of N.Y. & N.J., #129074/93,
2008 N.Y. App. Div. Lexis 374, 2008 NY Slip Op. 03991 (1st Dept.).
Several U.S. domestic organizations claimed that
they wished to provide support to "nonviolent and lawful" activities
of foreign organizations designated as terrorist organizations by the U.S.
government, and challenged the constitutionality of portions of the
USA Patriot Act providing such support. The foreign organizations in
question in the case are the Kurdistan Workers Party, aka Partiya Karkeran
Kurdistan ("PKK"), and the Liberation Tigers of Tamil Eelam
("LTTE"). A federal appeals court found that provisions of the
statute criminalizing the providing of training, expert advice or assistance to
terrorist organizations was unconstitutionally vague and improperly chilled
protected expressive activities, as well as providing criminal penalties
without adequately defining what conduct was prohibited. These provisions could
arguably be applied to protected free speech activities, the court stated. The
court rejected, however, the plaintiffs' argument that similar prohibitions on
providing "personnel" to such terrorist organizations was also vague,
since there is a difference between constitutionally protected expression and
unprotected actions or conduct. The court also upheld the criminalization of
facilitating terrorist activities through supplying expertise in constructing
explosive devices, supplying weapons, or providing money for terrorist
activities. Humanitarian Law Project v. Mukasey, No. 05-56753, 2007 U.S. App.
Lexis 28470 (9th Cir.).
Sheriff's deputies believed that a parked car was
"suspicious" because some boxes and a 5-gallon can could be seen
within it. The vehicle was observed within days of some
"controversial" international meetings being held in Miami, Florida
at which political demonstrations were anticipated, the Free Trade Area of the
Americas ("FTAA") ministerial hearings, in November 2003. Upon being
informed of the vehicle by the deputies, the officer in charge of the city's
bomb squad arrived on the scene and "rendered it safe" by destroying
it. The officer, based on the circumstances, was entitled to qualified immunity
and had at least "arguable" probable cause to take the actions he carried
out. Claims against the city will proceed. Vogel v. City of Miami, No.
07-20436, 2007 U.S. Dist. Lexis 85438 (S.D. Fla.).
The U.S. government has "plenary
authority" to control entry into the country through the border, and also
had statutory authority to detain and search five U.S. citizens, practicing
Muslims with no criminal records, when they were returning from a Canadian
Islamic conference. Additionally, intelligence the government had received that
persons with known terrorist ties would be attending the conference provided
the government with a compelling interest in preventing potential terrorists
from entering the county. The searches, which took place at the border were not
intrusive enough to violate the Fourth Amendment, and also did not violate the
plaintiffs' constitutional or statutory rights to religious freedom. Tabbaa v.
Chertoff, No. 06-0119, 2007 U.S. App. Lexis 27258 (2nd Cir.).
Information concerning whether or not the
plaintiff was listed in a Terrorist Screening Database (TSDB) maintained by the
FBI was protected from disclosure under a privilege for law enforcement
investigatory files. FBI's alleged surveillance of an Israeli native in the
U.S. did not violate his First Amendment rights. FBI agents were also not liable
for alleged harassment by his neighbors, who were under the mistaken belief
that he was Iranian, and when there was no evidence that any FBI agent was
aware of the plaintiff's particular political beliefs. Raz v. Mueller, No. CIV
02-5184, 389 F. Supp. 2d 1057 (W.D. Ark. 2005). [N/R]
Information concerning the frequency and location
of random searches of N.Y. subway riders' backpacks and containers were
protected against discovery by a law enforcement privilege in a lawsuit
challenging the city's program to carry out such searches. Macwade v. Kelly,
No. 05 CIV.6921, 230 F.R.D. 379 (S.D.N.Y. 2005). [N/R]
U.S. Supreme Court rules that foreign nationals
detained in Guantanamo Bay, Cuba, captured in Afghanistan hostilities, have a
right to access to U.S. courts to challenge the legality of their detention,
and that U.S. citizen detained as an "enemy combatant" for allegedly
fighting against the U.S. in Afghanistan, also had a due process right to
access to a "neutral decision maker" to challenge the factual basis
for his detention. In a third case involving a U.S. citizen detained as an
"enemy combatant" on U.S. soil for alleged involvement in terrorist
conspiracy, Court does not reach ultimate issues because of procedural defects
in court filing. Rasul v. Bush, No. 03-334, 2004 U.S. Lexis 4760; Hamdi v.
Rumsfeld, No. 03-6696, 2004 U.S. Lexis 4761; Rumsfeld v. Padilla, No. 03-1027,
2004 U.S. Lexis 4759. [N/R]
Two Wisconsin inmates did not have standing to
sue Middle Eastern nations such as Iran, Iraq, Syria, the Sudan, and Libya, and
terrorist groups such as Al Qaida and the Taliban for millions of dollars in
compensatory and punitive damages in a lawsuit filed with the purported
intention of "lending a hand" in the war on terrorism. They had personally
never been victims of terrorism and were "no more likely than the average
American citizen to be victims of future attacks." George v. Islamic
Republic of Iran, No. 02-3195, 63 Fed. Appx. 917 (7th Cir. 2003).[N/R]
U.S. Attorney General John Ashcroft rules that
illegal immigrants can be held indefinitely without bond if their cases present
national security concerns. The opinion was requested by the Homeland Security
Department, which now has authority over most immigration matters, after the Board
of Immigration Appeals upheld a judge's decision to release a Haitian
asylum-seeker on $2,500 bond. Ashcroft ordered that this decision be vacated,
and that the asylum-seeker be denied bond and detained "pending
appropriate disposition and proceedings respecting his status under the
immigration laws." In Re: D-J-, Respondent, 23 I&N Dec. 572 (A.G.
2003). Interim decision #3448, April 17, 2003. [N/R]
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