Patterico's Pontifications


Did Judge Batchelder Support President Bush on the Merits of the Legality of the NSA Surveillance Program?

Filed under: Civil Liberties,Constitutional Law,Court Decisions,General,Law — Patterico @ 1:49 pm

I have read yesterday’s decision on the NSA warrantless surveillance case. It is a complex set of issues and a complex decision, and I am no expert in this area, so everything I say in this post is necessarily tentative and offered for purposes of discussion.

With that caveat, I would like to (tentatively!) dispute Glenn Greenwald’s characterization of both majority opinions as completely agnostic on the merits. It seems to me that one of them (Judge Batchelder’s opinion) asserts quite clearly that, based on what is known about the surveillance program, it does not violate FISA or Title III of the Omnibus Crime Control and Safe Streets Act of 1968. Judge Batchelder’s assertions are offered as part of a standing analysis, and a ruling on standing grounds is not a ruling on the merits. But as Judge Batchelder describes it, the analysis of the plaintiffs’ standing on the statutory claims depends in part on whether there is a valid claim under those statutes — and, she says, there is not.

For example, at page 32, Judge Batchelder writes:

It is undisputed that the NSA intercepts international, rather than domestic, communications, so . . . Title III does not apply. Moreover, because the plaintiffs have not shown, and cannot show, that the NSA engages in activities satisfying the statutory definition of “electronic surveillance,” the plaintiffs cannot demonstrate that FISA does apply.

(All emphasis in this post is mine.)

Thus, I disagree with Glenn Greenwald when he insists that the ruling “had absolutely nothing to do with the merits of the case”:

[T]he majority opinion here did not make a single comment suggesting they believe Judge Taylor’s ruling on the merits was wrong, nor did they suggest that warrantless eavesdropping is legal. To the extent they commented on those issues at all, the majority opinion observed that the appeal “presents a number of serious issues,” while the other Judge in the majority (Gibbons) described in the first paragraph of her concurring opinion the “complexity” of the “merits issues.” Not a word in either of those two opinions constitutes a repudiation of the finding by Judge Taylor that the President broke the law and violated the Constitution.

Unlike the two judges in the majority, the dissenting judge (Gilman) did issue findings regarding the illegality of the NSA program once he found that the plaintiffs had standing to sue. And he decided conclusively that the NSA program violates FISA and that the administration’s two legal excuses are invalid. That means that the only two federal judges ever to rule on the legality of the NSA warrantless eavesdropping program — Judge Taylor and now Judge Gilman — have both decisively concluded that the President’s warrantless eavesdropping is illegal.

The language I quote from Judge Batchelder’s opinion above, I believe, contradicts (or at least significantly undercuts) Greenwald’s categorical assertion that no judge in the majority offered any opinion on the merits of any of the claims. Judge Batchelder clearly states that the plaintiffs show no statutory violation of Title III or FISA. In the extended entry, I go into detail regarding Judge Batchelder’s reasoning leading her to make that statement. But it seems to me — even though her conclusion in reached in service of a holding on standing grounds — the wording of Judge Batchelder’s analysis is inconsistent with Greenwald’s claim that “[n]ot a word in [her] opinion[] constitutes a repudiation of the finding by Judge Taylor that the President broke the law . . .”

Here are the details:

[Extended entry]

In her analysis of the plaintiffs’ standing on the statutory claims, Judge Batchelder writes that the

first step is to consider whether any of these statutes “authorize[] review at the behest of the plaintiff[s]” — i.e., whether these statutes (1) govern the NSA’s challenged conduct and (2) provide the plaintiffs a means of judicial review.

(P. 26.)

At page 29, Judge Batchelder writes that the NSA’s surveillance is not covered by Title III because of an explicit statement in that statute that it does not apply to surveillance of international communications for intelligence purposes:

The first clause of § 2511(2)(f) — stating that Title III does not govern the acquisition of “foreign intelligence information from international or foreign communications” — expressly disclaims application of Title III to surveillance activities of the type at issue in the present case. The NSA monitors international communications for the purpose of acquiring foreign intelligence about terrorist organizations; this type of surveillance falls squarely under the disclaimer found in the first clause of § 2511(2)(f).

In case there were any doubt about what she means, she writes at page 30:

Because the first clause of § 2511(2)(f) states that Title III does not apply to the internationally focused surveillance activities challenged in this case, the plaintiffs have not asserted a viable cause of action under Title III.

“[N]ot a word” repudiating Judge Taylor’s finding that the President broke the law? It seems to me that she has a whole section repudiating that finding. Actually, make that two sections — because Judge Batchelder makes a similar finding with respect to FISA, writing that the plaintiffs have not shown that the NSA surveillance at issue in the case is electronic surveillance as specifically defined by FISA:

Next, the interception must occur by “electronic surveillance.” According to the plaintiffs, the government’s admission that it intercepts telephone and email communications — which involve electronic media and are generally considered, in common parlance, forms of electronic communications — is tantamount to admitting that the NSA engaged in “electronic surveillance” for purposes of FISA. This argument fails upon recognition that “electronic surveillance” has a very particular, detailed meaning under FISA — a legal definition that requires careful consideration of numerous factors such as the types of communications acquired, the location of the parties to the acquired communications, the location where the acquisition occurred, the location of any surveillance device, and the reasonableness of the parties’ expectation of privacy. See 50 U.S.C. § 1801(f).40 The plaintiffs have not shown, and cannot show, that the NSA’s surveillance activities include the sort of conduct that would satisfy FISA’s definition of “electronic surveillance,” and the present record does not demonstrate that the NSA’s conduct falls within FISA’s definitions.

Judge Batchelder has a footnote setting forth the specific definition of “electronic surveillance” in FISA:

FISA defines “electronic surveillance” in exactly four ways:

(1) the acquisition by an electronic, mechanical, or other surveillance device of the contents of any wire or radio communication sent by or intended to be received by a particular, known United States person who is in the United States, if the contents are acquired by intentionally targeting that United States person, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes;

(2) the acquisition by an electronic, mechanical, or other surveillance device of the contents of any wire communication to or from a person in the United States, without the consent of any party thereto, if such acquisition occurs in the United States, but does not include the acquisition of those communications of computer trespassers that would be permissible under section 2511(2)(i) of title 18, United States Code;

(3) the intentional acquisition by an electronic, mechanical, or other surveillance device of the contents of any radio communication, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes, and if both the sender and all intended recipients are located within the United States; or

(4) the installation or use of an electronic, mechanical, or other surveillance device in the United States for monitoring to acquire information, other than from a wire or radio communication, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes.

50 U.S.C. § 1801(f). The present record, which contains three facts regarding the TSP, offers no indication as to where the interception may occur or where any surveillance device is located. Nor does it offer any basis to conclude that particular people located in the United States are being targeted.

The “three facts” about the TSP (“Terrorist Surveillance Program”) referred to in this footnote are set forth at page 6 of the opinion: “the NSA (1) eavesdrops, (2) without warrants, (3) on international telephone and email communications in which at least one of the parties is reasonably suspected of al Qaeda ties.” Judge Batchelder’s ultimate conclusion is stated at page 31: “No matter how these claims are characterized, the plaintiffs have not asserted a viable FISA cause of action.”

The dissent points to various public statements made by the Administration that suggest that the electronic surveillance (in common parlance) conducted by the NSA fits within FISA — in particular the Administration’s decision to subject the surveillance to the FISA court. Regardless of whether the dissent or Judge Batchelder has the better of the argument on this issue, it seems clear to me that Judge Batchelder is expressing a view (if not a “ruling”) on the merits of the plaintiffs’ claims, albeit in the limited context of a statutory standing analysis.

I’ll say it again: keep in mind that I may be wrong, and that my opinions are offered for the purposes of starting a discussion, and seeking commentary from people with more expertise on the issue. I’ll e-mail a few of the folks with expertise in this area and see if I can get a reaction from them.

P.S. Is the decision right? I don’t know. An opinion on the correctness of the decision on the standing issue would require delving into a number of Supreme Court decisions, something I have no interest in doing, especially on such a dry and technical issue. I don’t get paid to do it, and I suspect most of you aren’t any more interested in that issue than I am. (If you are interested in the issue, Ann Althouse has delved into the cases and summarized them neatly here, and Marty Lederman offers some insightful criticisms here. Orin Kerr appears to agree with the majority’s analysis.)

A thorough discussion of the correctness of the dissent’s view of the merits is beyond the scope of this post, and something I don’t have a firm opinion about. Suffice it to say that the dissent sets forth the best-reasoned and least hysterical case for the illegality of the surveillance program that I have yet read.

The result, in my view, turns largely on whether the AUMF set forth an exception to the exclusivity provision of FISA, due to the fact that surveillance is necessarily incidental to the use of force (and thus distinguishable from the particular form of military commissions at issue in the Hamdan case). (In my view, the resolution of this issue resolves the “inherent authority” argument as well, because it tells us which of the Youngstown categories governs the analysis of the President’s actions. John Hinderaker would probably kill me for accepting those categories as the law, but I believe that the current court will treat it as such.)

I tend to lean towards the Administration’s view on this issue, for the reasons I already expressed in this post — but the dissent’s argument is well argued and may well carry the day in the Supreme Court (especially given the fact that Justice Kennedy will doubtless be casting the deciding vote).

P.P.S. I will add that, whether or not the decision is proper as a legal matter, there is something a bit Kafkaesque about the notion that nobody can challenge the program’s allegedly illegal nature because it’s a secret.

33 Responses to “Did Judge Batchelder Support President Bush on the Merits of the Legality of the NSA Surveillance Program?”

  1. I just skimmed the case, and unless I missed something significant, it looks as though the dissenting judge greenwalded the question of whether TSP did or did not involve “electronic surveillances” for purposes of FISA. Without knowing where the wiretaps were conducted, it is impossible to know whether or not the government committed “electronic surveillances,” and if they didn’t, FISA by its terms does not apply.

    Xrlq (69d423)

  2. Greenwald also ignored the nice smackdown Judge Batchelder directed to the plaintiffs and Judge Taylor regarding the court exceeding its authority to intervene where a legislative remedy is clearly the solution. After a few citations followed by a lenthy SC cite, Judge Batchelder delivers the haymaker on page 26:

    I would post it if I knew how to extract from the pdf, but it ends as follows:

    “It would ill behoove us to exceed our authority in order to condemn the President or Congress for exceeding theirs.”

    Take that Judge Taylor and Glenn Greenwald!

    daleyrocks (906622)

  3. I think you’re right as far as Title III goes–in fact, I don’t think it’s possible to read that portion in any other way–but I think it’s much more ambivalent about FISA itself. I think it merely means that unless and until the plaintiffs can actually bring in evidence of electronic surveillance, and who and where it was performed, the plaintiffs can not sue. Whereat, of course, your PPS invoking Kafka comes into play.

    However, even if you are correct about FISA, saying that it is not illegal under Title III and FISA is not the same as saying it is not illegal under other laws, and definitely not the same as saying it is compatible with the BOR on search and seizure.

    kishnevi (2dbd61)

  4. kishnevi,

    If the case is being decided on summary judgment, and the judge is ruling that the plaintiffs haven’t made out a claim under FISA . . . isn’t that an opinion regarding the merits?

    That’s all I’m saying in the post.

    Patterico (2a65a5)

  5. I might have much more to say about this later when I have more time, but I noted that even the dissenter simply sat Judge Diggs’ opinion aside on the issue of the merits. Here’s his quote:

    “Without expressing an opinion regarding the analysis of the district court, I would affirm its judgment …”

    He then spends 8 pages setting forth why the TSP is a violation of FISA and T-III, but leaving aside all questions of Constitutional law since they aren’t necessary to determine the matter in his view.

    And he never once mentions the Digg’s opinion.

    wls (077d0d)

  6. Patterico – Batchelder expressly addresses your Kafka concern on page 26 in her dress down of the plaintiffs.

    Greenwald also dishonestly implies that by not addressing the substance of the earlier ruling on matters other than standing, the judges were unable to poke holes in Judge Taylor’s opinion, representing a victory for Judge Taylor on the illegality aspects of her opinion. Correct me if I’m wrong, but once you find an error in such a fundamental matter as standing to reverse an opinion, can’t you basically stop looking if you so choose. Opining on other matters just serves up additional meat to be attacked in potential future appeals.

    As usual, Greenwald only serves up the facts which make his argument.

    daleyrocks (5a4736)

  7. The concurrence agreed only as to the judgment.
    Doesn’t this all relate to that post you wrote complaining about the coverage in the LA Times and the meaning of the word “majority?”
    Am I missing something?

    AF (4a3fa6)

  8. Am I missing something?

    Indeed you are. Greenwald says that neither judge said anything to repudiate Judge Taylor’s decision regarding the merits. Yet Judge Batchelder did.

    Patterico (2a65a5)

  9. If I may be so bold, AF …

    I think AF had the same (technical, not ideological) question I did when I read your post. To wit:

    If the L.A. Times was wrong to say Roberts’ quote came from the “majority” opinion when Kennedy hadn’t signed on to it, then can the opinions of Batchelder and Gibbons properly be called “majority opinions” when they concurred on the judgment only?

    Not Rhetorical (9a6a37)

  10. I’m not a lawyer, and perhaps my view is a bit reductionist, but isn’t this notion of standing vs. merit a false dichotomy? If no one can show standing, that is because no one can show he has been wronged by the government’s actions. Kafka’s Joseph K, in contrast, faced punishment in The Trial.

    It seems to me that so long as the NSA, or the Executive as a whole, is a black box keeping the information to itself — and not for example, using it as evidence in court — there is no one needing relief from action of the Executive.

    Such a stance fits with the usual remedy for illegally obtained evidence (its exclusion from any trial), would seem to fit the need for military intelligence without the Judiciary constantly patrolling its boundaries, and also keeps the Judiciary out of exclusively internal affairs of the Executive.

    I will grant that one potential problem with such a stance is the possibility of a massive buildup of intelligence over time, which may at some point in the future be used for some radical or illegal action (e.g., something akin to post-Pearl Harbor Japanese internment), at which time the Judiciary may be ineffectual.

    On the other hand, the government’s use of such tactics doesn’t depend on NSA data detection — indeed, the NSA data detection could be used in lieu of, say, locking up all the Muslims after a nuclear attack — and the problem, if it were one, of the Judiciary acquiescing to such action, is hardly one to which the Judiciary can object now. (It is a weak argument to say “we must stop you now because we might not have the will to meet our duty to stop you in the future.”)

    DWPittelli (2e1b8e)

  11. Not Rhetorical,
    that was the question, specifically.

    AF (4a3fa6)

  12. There is really no single “majority opinion” in the case. The controlling opinion is the narrower concurrence in the judgment. Greenwald is imprecise, then, when he uses the term “majority opinion” to refer to Batchelder’s opinion, as he does in this sentence:

    To the extent they commented on those issues at all, the majority opinion observed that the appeal “presents a number of serious issues,” while the other Judge in the majority (Gibbons) described in the first paragraph of her concurring opinion the “complexity” of the “merits issues.”

    This is a reference to Batchelder’s opinion as the “majority” opinion, when in fact it would be better to call it the “lead” opinion — or simply Batchelder’s opinion. I think it’s fine to refer to the “majority opinions” collectively, as I do in the post, but it is wrong to call Batchelder’s single opinion “the” majority opinion, as Greenwald does. (I think it would also be misleading to call Gibbons’s opinion “the” majority opinion; better to call it the controlling opinion.)

    So AF points out another error in Greenwald’s post. But one error does not cure another. Greenwald is incorrect to say that “the majority opinion here [by which, in context, he means Batchelder’s lead opinion — see the block quote above] did not make a single comment suggesting they believe Judge Taylor’s ruling on the merits was wrong, nor did they suggest that warrantless eavesdropping is legal.”

    Nor is he correct to say: “Not a word in either of those two opinions constitutes a repudiation of the finding by Judge Taylor that the President broke the law and violated the Constitution.” Judge Batchelder has two sections doing exactly that: repudiating that finding as regards Title III and FISA.

    Patterico (2a65a5)

  13. Paterico – It’s a typical Greenwald post, lazy on the facts because he doesn’t expect his readers to click on any links. As frequently happens with his posts, when you take the trouble to follow the links, they tend to disprove the points he is attempting to make. It is a phenomenon that has been much commented upon.

    You are quite right to correct his analysis in you post. I was more focused on his blatant intellectual dishonesty about the judges focusing on standing rather than the legality of the TSP as a validation of the remainder of Judge Taylor’s opinion.

    daleyrocks (5a4736)

  14. Two tt’s – sorry

    daleyrocks (5a4736)

  15. i only read the first ten pages, because it’s a gorgeous, gorgeous day here on the southern oregon coast, but george orwell was talking to lewis carroll and i knew where it would end up.

    there should be no “state secrets doctrine” in a free country. there may be state secrets themselves, but no doctrine to pervert the quest for truth. there is no constitutional foundation for it, it was born in the reynolds case; widows of an air force plane crash suing the government for negligent maintenance of the aircraft. the government asserted state secrets and prevailed. much, much later it was revealed that the government’s allegations of proper maintenance were false. the doctrine was used to conceal a lie. what overarching, redeeming social benefit was served by this? i can think of none. even if the aclu had evidence of specific eavesdropping subjects in hand, the court could tell them they have no evidence, and consequently lack standing, and that’s nothing more than a life-tenured red queen in a black robe.

    i lived during the early 1970’s, when the judiciary did a pretty good job of checking and balancing an out-of-control executive. some subsequent executives appointed a lot of executive-deferential judges, and now we have an unaccountable executive and our judiciary ain’t worth shit. hooray! time for gardening now.

    assistant devil's advocate (60f8aa)

  16. I agree that there is no “majority” opinion; however, I think it would be only the most technical of a foul to refer to Judge Gibbons’s opinion as the majority opinion, as it doesn’t stake out any real positions not shared by Judge Batchelder’s. To the extent the two opinions overlap, they are the majority opinion in every meaningful sense of the word.

    Xrlq (69d423)

  17. X,

    I agree with you there. But I think AF is trying to defend Greenie as accurate by pretending that he was referring to Gibbons’s opinion when he said “majority opinion” — and that’s not how Greenwald used that phrase.

    Patterico (2a65a5)

  18. Enoying the discussion. Since I don’t “know” law, I need to read everything twice, however, are you all talking about the sockpuppet, Glenn Greenwald? If so, why?

    Sue (fa8402)

  19. How about this for a defense of the program…
    since when is is it a bad thing to spy on the enemy during war time, and since when did the Commander in Chief ever need a warrant before doing it? Look at that, and I never even went to law school.

    mike volpe (dc9e21)

  20. The “Majority” Opinion belongs to the judge who was assigned to write the opinion on the outcome of the case. The assignment is given out by the senior judge on the prevailing side.

    Batchelder is senior to Gibbons.

    They both voted to reverse the lower court judgment, and Batchelder assigned the writing of the majority opinion to herself.

    Gibbons has as choice as to what parts of the opinion she agrees with and joins. Her concurrence in the judgment decides the case.

    But, Batchelder’s opinion is the Opinion of the Court, and it is the “majority” opinion as to the matters Gibbon’s concurs in.

    wls (077d0d)

  21. […] Patterico did a decent job debunking the latest effluvium from Ellers McEllerson, claiming that the Sixth Circuit’s decision on the NSA warrantless surveillance case “had absolutely nothing to do with the merits of the case,” as far as Patterico went.  But inasmuch as Patterico admits he is not an expert on the issue of standing to sue in federal court, I would add that Patterico ended up going light on the Gleen(s). […]

    The Sock-Puppet of the Baskervilles [Karl] (e95a11)

  22. Look at that, and I never even went to law school.

    It shows.

    Andrew J. Lazarus (af2bc7)

  23. Reading through Gilman’s dissent, his position on standing strikes me as exactly how the plaintiff’s bar bankrupted a good part of American industry via junk science in mass tort lawsuits. By representing plaintiffs who were not currently ill, but had a fear of becoming ill, who may have been exposed to a substance which may or may not cause an illness which may or may not have been produced by the specific defendant. Negotiating settlements for plaintiffs who are not currently ill gives them a slice of the pie while it is still there, while making it smaller for legitimately ill plaintiffs making it harder for the defendants to continue in business, but hey, the larger the settlement, the bigger the fees.

    Similarly, the plaintiffs in the current case had no evidence that they were being surveilled, merely a suspicion that they might because they were in the habit of talking to slimeballs overseas, and thus deserved their whack at the judicial pinata. They were afraid and needed redress, even though, as the “majority” pointed out, they could be surveiled under FISA anyway. How could these dirtball plaintiffs tell whether they were being monitored by the TSP, with or without warrants, or FISA?

    Fear is a great thing in the hands of the right attorney and in front of the right activist judge. Gilman’s got some interesting free speech, equal protection, death penalty, and religion decisions in his background. He’s clearly not afraid to dissent.

    daleyrocks (906622)

  24. I was only commenting in re: Pat’s complaints about the LA Times.
    I like Greenwald well enough, but he works in broad strokes and gets sloppy. Pat attacks details in G.G’s arguments but mostly those more important as matters of politics than law; and Pat generally steers clear of responding to more careful analysis, for instsnce what one would find here.
    Marty Lederman on the Sixth Circuit Opinions in the TSP/FISA Case, is here

    AF (4a3fa6)

  25. AF – Patterico already provided the Lederman link above. If you like your analysis with huge leaps of fantasy, unfounded assumptions on how the program works to support your conclusions, and rampant speculation, then Lederman and Greenwald are the choices for you. Marty’s post on the decision is ridiculous with the amount of unsupported crap it includes. Try reading the decision itself as a starting point, though.

    daleyrocks (906622)

  26. daleyrocks,
    you got me on Pat’s link to Lederman. My [glib] bad. You opinion of what he says is something else.

    AF (4a3fa6)

  27. I’ll be more direct.
    “Pat generally steers clear of responding to more careful analysis,”
    Not this time. Pointing to that analysis, acknowledging it and saying there’s not enough time to respond is more than enough.
    I owe Pat an apology.

    Twice in a month.
    I’m slipping.

    AF (4a3fa6)

  28. The result, in my view, turns largely on whether the AUMF set forth an exception to the exclusivity provision of FISA, due to the fact that surveillance is necessarily incidental to the use of force

    I’ve always found the AUMF argument unsatisfying, since FISA explicitly provides even for a formal declaration of war. Basically, in wartime the same rules apply with some modification (a longer period for retroactive warrants). We, or at least I, normally think of the AUMF as something like an informal formal declaration of war, so I would expect it to give the government at most the equivalent powers that a declaration of war would. But the AUMF argument requires that at least for this purpose the AUMF was something more than a declaration of war.

    Now when we’re talking about legal arguments “unsatisfying” doesn’t necessarily mean wrong. The Kafkaesque standing argument — which even Greenwald concedes may be correct — is a case in point.

    Crust (399898)

  29. So was electronically spying on Russia, for example placing electronic pods over their undersea telephone cables, illegal? There was no declaration of war. And possibly those Russian sailors were calling their American call girls. That would make it domestic criminal investigation.

    Yes, I think that Kennedy and Johnson were quite the criminals.

    Or maybe the Executive has war making powers that do not require a declaration of war. Do you think?

    Red (e07696)

  30. AF – Congratulations! Admitting you have a problem is the first step to recovery. But let’s face facts kiddo, you had nothing to slip from, you been at the bottom for a while.

    daleyrocks (906622)

  31. I believe the argument regarding that, Crust, is that regardless of what FISA says, the Executive has certain powers inherent in the state of War and its prosecution, which allow it to do those things in that context.

    (One may or may not agree with that argument, either on its merits, or for political reasons, naturally.

    But that’s what I understand the Executive’s position on the program related to the AUMF to be – that FISA’s restrictions in this specific case are irrelevant because FISA can’t restrict the proper powers of the Executive like that.

    Eventually that might get sorted out by the courts, once someone has standing to sue and does.)

    Sigivald (9ca8d0)

  32. Sigivald, that’s a different argument than the one I think Patterico is making.

    As I understand it, there are basically two main legal arguments:

    One is a statutory argument, that the “all necessary and appropriate force” language of the AUMF for Afghanistan and al Qaeda overrode FISA for surveillance connected to that war.

    The second argument is a constitutional argument that the President has an inherent surveillance power of some type that can’t be limited by statute (and includes at least some surveillance that FISA purports to limit by requiring judicial review).

    I think Patterico is principally talking about the first argument and you’re talking about the second argument. Patterico does mention the second argument in his parenthetical where he jokes about Hinderaker killing him, but I take him to be saying that the key is the AUMF argument: if that fails, the inherent powers argument ain’t going to stand either. But maybe I’ve misread him.

    Crust (399898)

  33. […] of the case. The anonymous legal blogger "Patterico" has an interesting summary of that here. __________________ Our honor defend, we will fight to the end for […]

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