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Iran/Arms Transaction: Legal Memoranda - Nicaraguan Contra Aid [Boland Amendment]
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Iran/Arms Transaction: Legal Memoranda - Nicaraguan Contra Aid [Boland Amendment]
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Ronald Reagan Presidential Library Digital Library Collections This is a PDF of a folder from our textual collections. Collection: Culvahouse, Arthur B.: Files Folder Title: Iran/Arms Transaction: Legal Memoranda - Nicaraguan Contra Aid [Boland Amendment] (1) Box: CFOA 1131 To see more digitized collections visit: https://reaganlibrary.gov/archives/digital-library To see all Ronald Reagan Presidential Library inventories visit: https://reaganlibrary.gov/document-collection Contact a reference archivist at: [email protected] Citation Guidelines: https://reaganlibrary.gov/citing National Archives Catalogue: https://catalog.archives.gov/ THE WHITE HOUSE WASHINGTON new file September 17, 1984 MEMORANDUM FOR FRED F. FIELDING FROM: RICHARD A. HAUSER RAS SUBJECT: "Neutrality Act" Attached, as requested, is a copy of 18 USC $960, the so-called "Neutrality Act", along with a copy of a recent New York Times article on issues relating to this statute, and relevant sections of the Department of Justice's brief in Dellums V. Smith. Attachments A 18 § 959 CRIMES Pt. 1 Note 14 Ch country. and from the action of third 16. Examination of witnesses persons with whom he perfects the en- The persons alleged to have been hired Gen listment which he may have contracted in may testify as to their intent without Act the United States. U. S. v. Hertz. C.C. criminating themselves. U. S. V. Kazin- Pa.1855, 3 Pittsb.Leg.J.(Pa.) 194, 26 Fed. ski, D.C.Mass.1855, 2 Sprague 7, 26 Fed. Cas.No.15.357. Cas.No.15,508. 13. Weight and sufficiency of evidence 17. Verdict In a proceeding to remove a person to On a trial for violation of former sec- another state in which he was indicted tion 22 of this title [now this section] for conspiring to retain a citizen to enlist the court had no power (i) direct the in the Mexican revolutionary forces. evi- jury to return a verdict of guilty, pursu- dence tended to show a violation of ant to an agreed statement of facts be. former section 22 of this title [now this tween the government and the defendant. section] and to show probable cause for regardless of the jury's own view re- believing defendant guilty of conspiring specting the proper conclusion to be to compass such violation. Gayon V. drawn from the facts agreed upon. Blair McCarthy, N.Y.1920. 40 S.Ct. 2H. 252 U.S. V. U. S.. Cal.1917. 241 F. 217. 134 C.C.A. 171. 64 L.Ed. 513. 137. § 960. Expedition against friendly nation Whoever, within the United States. knowingly begins or sets on foot or provides or prepares a means for or furnishes the money for. or takes part in, any military or naval expedition or enterprise to be carried on from thence against the territory or dominion of any for- eign prince or state. or of any colony. district. or people with whom the United States is at peace, shall be fined not more than $3,000 or imprisoned not more than three years, or both. June 25, 1948, c. 645, 62 Stat. 745. Historical and Revision Notes Reviser's Note. Based on Title 18. C. Reference to territory or possessions of S.C.. 1940 ed., $ 25 (Mar. +. 1909. c. 321, $ the United States was smitted as covered 13. 35 Stat. 1090: June 15. 1917. c. 30. Ti- by definitive section 5 of this title. tie V. 15. 40 Stat. 223). Canal Zone. Applicability of section Words "within the United States" were Canal Zone. see section 11 of this title. substituted for "within the jurisdiction" etc., in view of the definition of United States in section 5 of this title. Cross References Foreign translents, application of section to, see section 959 of this title Jurisdiction of offenses. see section 3241 of this title. Letters. writings. etc.. in violation of this section as nonmailable. -08 section 1717 of this ritle. Library References International Law $10.18. C.J.S. International Law $ 16. Notes of Decisions I. GENERALLY 1-30 II. OFFENSES 31-60 III. PROSECUTION AND PUNISHMENT 61-71 300 B DATE: 9-12-84 The New York Times PAGE: BIO Neutrality and Private Adventures By STUART TAYLOR Jr. ment's chief spokesman, explained to avoid the appearance of circum- Monday that the Administration de- venting Congressional restrictions. Special to The New Yort Times cided earlier this year not to discour- But the more the Administration WASHINGTON, Sept. 11 - The neutrality laws, enacted almost two age "legal" private American sup- argues that private groups support- centuries ago to bar the organizing in port of the rebels in Nicaragua sup- ing military attacks are acting on ported by the Central Intelligence their own, the more its critics de- the United States of private military Agency. mand that it prosecute the private attacks against other nations, have Asked today what kind of support groups under the neutrality laws. become something of a headache for American policymakers in the era of was legal, two other State Depart- Washington Supported It ment officials, who refused to speak covert intelligence operations. The Neutrality Act of 1794, the If read broadly today, as they were provision most often cited by critics by some courts in the 19th and early of the legality of the Administration's 20th centuries, these laws could make Core of issue is use support for attacks on Nicaragua, it a crime for people in the United was enacted with President Washing- States, perhaps including the Presi- ton's support to prevent the weak new dent, to provide financial and other of third country country from being dragged into for- eign conflicts by adventurers. support for Nicaraguan rebels. as launching point. The law states: "Whoever, within Some Congressional Democrats, the United States, knowingly begins Nicaragua's Sandinista Govern- or sets on foot or provides or prepares ment, have taken precisely this posi- a means for or furnishes the money tion in the controversy that has flared for, or takes part in, any military or anew since two Americans were for attribution, said that in the Ad- naval expedition or enterprise to be killed in Nicaragua Sept. 1. Their ministration's view the neutrality carried on from themce against the belicopter was downed in a rebel raid laws prohibited only the direct territory or dominiom of any foreign from Honduras into Nicaragua. launching of private military expedi- prince or state, or of any colony, dis- But administrations in the modern tions from the United States, not the trict or people with whom the United era have not read the neutrality laws provision of financial or other support States is at peace, shall be fined not broadly. "Clearly they were not de- to insurgencies or military expedi- more than $3,000 or imprisoned not signed for the kind of situation which tions launched from third countries. more than three years, or both." exists in the world today," an Attor- This logic would immunize from The law was applied quite broadly ney General once said. prosecution those who raised money by several lower Federal courts in the Nothing Criminal' Noted in the Unitd States to send to Nicara- 19th and early 20th centuries. For ex- "Nor is an individual prohibited guan rebels in third countries-sucifes ample, in a 1921 decision, several peo- Honduras and those who traveled to from departing from the United ple were convicted of conspiring in such countries to enlist in forces at- the United States, in World War I, to States, with others of like belief, to join still others in a second country tacking Nicaragua. launch an invasion of India from for an expedition against a third coun- Attorney General William French Thailand and the Phillipines. Smith has also argued in a pending But the law has been used in only a try. There is nothing criminal in an lawsuit that the neutrality laws do not individual leaving the United States handful of prosecutions in recent dec- apply to the President or other offi- ades. And the archaic flavor of the with the intent of joining an insurgent group There is nothing criminal in cials supporting private military language suggests the difficulty of ap- his urging others to do so." operations abroad that are part of the plying this law in a world very differ- President's "official foreign policy." ent from the one for which it was writ- That Attorney General was Robert F. Kennedy. He was explaining after Judge Orders and Inquiry ten. It contains ambiguities enough to the failure of the Bay of Pigs invasion Judge Stanley A. Weigel of Federal provide grist for both sides. in 1961 why there was DO problem District Court in San Francisco dis- And Representative Don Edwards, under the neutrality laws with organ- agreed last year, saying that the neu- Democrat of California, accused the izing of Cuban exiles in the United trality laws were intended in part to Administration this week of "selec- States to make a military attack on keep the President from entangling tive enforcement of the laws" by con- Cuba, with Central Intelligence the nation in hostilities without a Con- doning private support for the Nica- Agency support. After all, Mr. Ken- gressional declaration of war. ragua rebels. nedy reasoned, the immediate base Judge Weigel ordered a special in- But one of the two State Depart- for the operation was Central Amer- vestigation to determine whether ment officials said today that the Ad- ica, not the United States. President Reagan and others had vio- ministration's consistency in taking a Judy Pond, & Justice Department lated criminal neutrality laws by sup- narrow approach to the neutrality spokesman, refused to comment to- porting rebel attacks against Nicara- laws was illustrated by its not prose- day when asked whether it violated gua, even though Congress appropri- cuting groups raising money for left- the neutrality laws for private Amer- ated $24 million for covert operations ist rebels in El Salvador, the Irish Ra ican groups to help finance and join in for the 1984 fiscal year. A Justice De- publican Army or other bostile for military attacks on Nicaragua, as did partment appeal is pending. eign rebels either. two Americans. Meanwhile, Congress seems un- "These guys are fairly clever and But while the Federal Bureau of In- likely to appropriate funds for covert they get lawyers to stay clear of any vestigation has reportedly investi- operations in Nicaragua for the 1985 violations of the laws,' this official gated such activities, the narrow fiscal year, which begins Oct. 1. said. "Occasionally we catch some- Kennedy interpretation of the neu- While the Administration says it has body who was dumb enough to launch trality laws seems to have some ap- decided not to discourage private his expedition from the United States peal to the Reagan Administration. groups from stepping in to support rather than from some other country, John Hughes, the State Depart- the Nicaraguan rebels, it has sought but not very often." DOJ 1983-04 8 C No. 84-1525 IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT RONALD V. DELLUMS, et al., Plaintiffs-Appellees, V. WILLIAM FRENCH SMITH, U.S. Attorney General, et al. Defendants-Appellants. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA BRIEF FOR THE APPELLANTS RICHARD K. WILLARD Acting Assistant Attorney General JOSEPH P. RUSSONIELLO United States Attorney LEONARD SCHAITMAN JOHN F. CORDES HAROLD J. KRENT Attorneys, Civil Division-Appellate Staff, Room 3127 Department of Justice Washington, D.C. 20530 Telephone: FTS 633-4214 IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT No. 84-1525 RONALD V. DELLUMS, et al., Plaintiffs-Appellees, V. WILLIAM FRENCH SMITH, U.S. Attorney General, et al. Defendants-Appellants. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA BRIEF FOR THE APPELLANTS QUESTIONS PRESENTED 1. Whether the Ethics in Government Act, which establishes a special procedure for investigating and prosecuting criminal allegations against high-level government officials, confers standing to sue on private persons, or permits private judicial enforcement actions. 2. Whether the Attorney General reasonably concluded that the Neutrality Act of 1794 does not criminalize acts of government officials taken in pursuit of official foreign policy objectives. 3. Whether the legality of the President's policy toward Nicaragua poses a justiciable question. STATEMENT OF THE CASE 1. Jurisdiction A. The district court exercised jurisdiction under the general federal question jurisdictional grant, 28 U.S.C. § 1331. B. This Court possesses jurisdiction under 28 U.S.C. § 1291, the provision allowing appeals from district court final decisions. C. The district court order is properly appealable, as it completely disposes of the case. D. The appeal is timely. The district court entered judgment on November 3, 1983. The government filed a timely motion to alter the judgment under FED.R.CIV.P. 59 (e). The district court entered an order denying that motion on January 10, 1984. The government filed a notice of appeal on that same day. The appeal, therefore, was timely under FED.R.APP.P. 4(a)(4). , 2. Nature of the Case = The Ethics in Government Act requirës the Attorney General to conduct a preliminary criminal investigation of high-level government officials upon receiving incriminating information that the Attorney General determines is sufficiently specific and credible. 28 U.S.C. §§ 591-592. The Attorney General then must notify a special division of the District of Columbia Circuit either that no further investigation is warranted or that independent counsel should be appointed to pursue the matter further. 28 U.S.C. § 592 (b) (1), (c) (1). In this case, the district court ordered the Attorney General to conduct a "preliminary investigation" under the Ethics Act (ER - 2 - 206-07) 1 The court based its decision on plaintiffs' claim that the President and various, Cabinet officers had violated the Neutrality Act of 1794 (18 U.S.C. § 960) in "supporting paramilitary operations against Nicaragua" (ER 171). The district court issued two opinions rejecting the government's arguments that (1) private persons lack standing to enforce the Ethics Act, (2) the Attorney General's Ethics Act decisions are unreviewable, (3) the Neutrality Act issue involves sensitive foreign policy concerns and therefore is non-justiciable, and (4) in any event, the Attorney General reasonably has construed the Neutrality Act not to apply to official government activities. The government took an immediate appeal (ER 327), and obtained a stay pending appeal from this Court (ER 328). 3. The Ethics In Government Act The Ethics in Government Act was enacted in 1978, and amended in 1983. The portions of the Act applicable to this case establish an investigatory and prosecutorial procedure for handling criminal allegations against high-ranking government officials. 28 U.S.C. §§ 49, 591-598. The Ethics Act applies to criminal allegations against the President and Vice President, cabinet-level officers, and certain other high-ranking government officials or participants in presidential campaigns. 28 U.S.C. § 591(a), (b). The Act states that, "[u]pon receiving information that the Attorney General determines is sufficient grounds to investigate * * * the Attorney General shall conduct, for a period not to exceed 1 "ER" stands for the Excerpts of Record we have filed pursuant to Local Rule 13(a). - 3 - ninety days, such preliminary investigation of the matter as the Attorney General deems appropriate." 28 U.S.C. § 592 (a) (1). "In determining whether grounds to investigate exist, the Attorney General shall consider -- (A) the degree of specificity of the information received, and (B) the credibility of the source of the information." 28 U.S.C. § 592(a)(1). After completing the preliminary investigation, the Attorney General must notify a special division of the District of Columbia Circuit, established for the purpose of appointing independent counsel. 28 U.S.C. §§ 49, 592 (b), (c). The Attorney General's notification is to indicate either that "no further investigation or prosecution is warranted," in which case "the court shall have no power to appoint an independent counsel" (28 U.S.C. § 592(b)(1)), or that "further investigation or prosecution is warranted," in which case "the Attorney General shall apply to the division of the court for the appointment-of an independent counsel" (28 U.S.C. § 592(c)(1)). Such applications "shall not be reviewable in any court." 28 U.S.C. § 592(f). In addition, whether the Attorney General applies for appointment of independent counsel or not, the Attorney General's report to the special court may not be revealed "without leave of the *** court." 28 U.S.C. §§ 592 (b) (3), (d) (2). When the special court receives an application for appointment of independent counsel, it must "appoint an appropriate independent counsel and *** define that independent counsel's prosecutorial jurisdiction." 28 U.S.C. § 593(b). The independent counsel "shall have *** full power and independent authority to exercise all investigative and prosecutorial functions and powers of the - 4 - Department of Justice ***." 28 U.S.C. § 594 (a). The independent counsel must, "except where not possible, comply with the *** established policies of the Department of Justice respecting enforcement of the criminal laws." 28 U.S.C. § 594(f). The Ethics Act also establishes an alternate triggering mechanism. "A majority of majority party members or a majority of all nonmajority party members of the Committee on the Judiciary of either House of the Congress may request in writing that the Attorney General apply for the appointment of an independent counsel." 28 U.S.C. § 595(e). The Attorney General must make a written response to the Congressional committee inquiry within 30 days of its receipt, or within 15 days of the completion of a preliminary investigation, whichever deadline is later. Ibid. The Attorney General's written response is to remain confidential unless the Congressional committee chooses to make it public-upon a finding of no prejudice to the rights of-any individual. Ibid. 4. This Litigation On January 27, 1983, the three individuals who now are plaintiffs in this lawsuit -- a Congressman from California (Ronald V. Dellums), a resident of Florida (Eleanor Ginsberg), and a resident of Nicaragua (Dr. Myrna Cunningham) -- submitted a letter to the Attorney General demanding appointment of a "special prosecutor" under the Ethics in Government Act (ER 18-23). The letter claimed that seven public officials covered by the Ethics Act had violated federal criminal law: President Ronald Reagan, ex- Secretary of State Alexander M. Haig, Jr., current Secretary of State George P. Shultz, Assistant Secretary of State Thomas O. Enders, Secretary of Defense Caspar Weinberger, Deputy Assistant - 5 - Secretary of Defense Nestor Sanchez, and Director of Central Intelligence William Casey (ER 18). These officials' purported "crimes" arise out of the United States' Central American policy, particularly its allegedly improper backing of an insurgency in Nicaragua (ER 18-23). Plaintiffs' January 27, 1983, letter 2 detailed numerous military- type activities allegedly taken by the United States government in furtherance of its Nicaragua policy, and concluded that public officials who participate in supporting non-wartime military operations against a foreign government are guilty of criminal misconduct (ER 19-22). Plaintiffs cited Criminal Code provisions that bar (1) military action against a foreign nation with whom the United States is at peace (the Neutrality Act, 18 U.S.C. § 960), (2) conspiracy to destroy foreign government property (18 U.S.C. § 956), and (3) transportation of firearmstin foreign commerce- (18 U.S.C. $ 922) (ER 22-23). On March 18, 1983, the then-Assistant Attorney General for the Criminal Division, D. Lowell Jensen, sent a letter to plaintiffs denying their request for appointment of a "special prosecutor" (ER 67). Mr. Jensen explained that the "material you provide does not. constitute specific information of a federal offense 'sufficient to constitute grounds to investigate' as required by the Ethics in 2 Plaintiffs attached to their letter a copy of the complaint they and others had filed in Sanchez-Espinoza V. Reagan, No. 82- 3395 (D.D.C.) (ER 24-66). The Sanchez-Espinoza complaint sought damages and injunctive relief for the government's allegedly illegal Nicaragua policy. The district court, however, dismissed the complaint under the political question doctrine. Sanchez-Espinoza V. Reagan, 568 F. Supp. 596 (D.D.C. 1983) appeal pending, No. 83-1997 (D.C. Cir.). - 6 - Government Act as amended on January 3, 1983" (ER 67). Several months later, in July, 1983, plaintiffs filed this lawsuit against the Attorney General, William French Smith, and 3 against Assistant Attorney General Jensen (ER 1-17). The complaint alleges that plaintiffs' January 27 submission to the Attorney General presented sufficient information of criminal violations by the President and senior Administration officials to warrant a "preliminary investigation" under the Ethics Act (ER 4- 5). The complaint points to a variety of injuries resulting from the alleged violations (ER 3). Plaintiff Dellums claims, as a member of Congress, a deprivation "of his constitutional right to participate in the decision to declare war, grant letters of marque and reprisal, and raise and support armies" (Id.). Plaintiff Ginsberg, who lives in Florida where plaintiffs say there are paramilitary training camps, claims a "nuisance," and the loss "of her right to the peaceful enjoyment of her property" (Id.) Plaintiff Cunningham claims "kidnapping and rape at the hands of insurgent forces" in Nicaragua that were "trained, armed, and funded at the direction of the President and other U.S. officials * **" (Id.). Based on these allegations, plaintiffs' complaint demanded a preliminary investigation under the Ethics Act, or alternatively, appointment of independent counsel (ER 16). 5. District Court Decisions On November 3, 1983, the district court entered summary 3 Stephen S. Trott now has succeeded Mr. Jensen as Assistant Attorney General for the Criminal Division, and pursuant to FED.R.APP.P. 43 (c) he should be substituted for Mr. Jensen as a defendant in this lawsuit. - 7 - judgment for plaintiffs (ER 206-07). The judgment required the Attorney General, by February 1, 1984, to conduct and complete a "preliminary investigation *** relating to violations of the I Neutrality Act, 18 U.S.C. § 960" (Id.). The court reasoned that plaintiffs' claim of Neutrality Act violations was "sufficiently specific" and "credible" to warrant an Ethics Act investigation (ER 174). The court stressed that it was not declaring "illegal any action by the President or his subordinates," only "that the Executive actions alleged by plaintiffs, if true, may violate federal law" (ER 174, 204). The district court rejected the government's argument that the Ethics Act does not contemplate private enforcement suits (ER 177- 90). The court acknowledged that plaintiffs' claims of harm from "the underlying criminal acts" were too "speculative" to confer standing to sue (ER 200). The court found "the requisite interest for standing, " however, in the Ethics Act itself -- which, according to the district court, grants "all members of the public" a "procedural right" that incriminating information they submit "will be forwarded and considered by appropriate decisionmakers" (ER 178-80). The court concluded from this, despite the Ethics Act's failure expressly to authorize private suits, that "Congress conferred upon [plaintiffs] a right to a judicial determination" (ER 180). The court also held that the Attorney General's refusal to conduct an Ethics Act investigation is reviewable because of the Administrative Procedure Act's "strong presumption of the right to judicial review" (ER 184 et seq.). Absent private enforcement suits, the district court believed, the Ethics Act would be rendered "a nullity" (ER 183). - 8 - Finally, the court rejected the government's "political question" argument that the judiciary ought not adjudicate sensitive foreign policy matters (ER 190-94). The court reasoned that plaintiffs' suit does "not directly challenge the legality of any action taken by the President," but "seek[s] only to compel good faith performance of a statutory duty" (ER 192). The government immediately filed a motion under FED.R.CIV.P. 59 (e) to alter the district court's judgment (ER 208-44). The government argued that the Attorney General reasonably had concluded that the Neutrality Act does not apply to official government activities, thus obviating any need for an Ethics Act investigation (Ibid.). The district court rejected the government's position (ER 305-21). Relying on the "history of the Neutrality Act and judicial precedent," the court found that plaintiffs' "contention that the Neutrality Act reaches executive officials is at least as persuasive as defendants' claim that it does not" (ER 309, 314). The court also concluded that various indications that Congress had sanctioned the government's Nicaragua policy through legislation "do not justify the Attorney General's refusal to conduct a preliminary investigation" (ER 313-14). The government promptly took an appeal (ER 327). After the district court refused to stay its judgment pending the appeal (ER 322-26), the government on January 25, 1984, obtained a stay from this Court (Pregerson and Kennedy, JJ.) (ER 328). STATUTORY PROVISIONS INVOLVED The text of the Ethics in Government Act (28 U.S.C. §§ 591-98) and of the Neutrality Act (18 U.S.C. § 960) is reproduced in an addendum to this brief. - 9 - II. THE NEUTRALITY ACT DOES NOT REACH THE CONDUCT OF GOVERNMENT OFFICIALS ACTING PURSUANT TO OFFICIAL GOVERNMENT POLICY Introduction The district court held that plaintiffs' allegations "could * & 7. reasonably be construed as involving a federal crime" under the Neutrality Act, and therefore, that the Attorney General had no choice but to conduct a preliminary investigation (ER 309). But the Attorney General, the nation's chief law enforcement officer, must determine as a threshold matter under the Ethics Act whether the facts alleged amount to a criminal violation. The statute makes clear that a preliminary investigation is only necessary upon receipt of "information that the Attorney General determines is sufficient to constitute grounds to investigate." 28 U.S.C. 592 (a) (1) (emphasis added). Based upon reasoned legal judgment and the overwhelming evidence of Congressional intent, the Attorney General has concluded that plaintiffs' allegations, even if true, simply do not constitute a federal crime -- namely, that Section 5 of the Neutrality Act, 18 U.S.C. 960, does not proscribe acts taken in pursuit of official governmental policy. 7 Assuming standing and reviewability, the Attorney General's view of federal criminal statutes is at least entitled to considerable deference. Under the APA, the Attorney General's 7 The district court inexplicably asserted that the Attorney General has enunciated a policy not to prosecute federal officials under the Act (ER 314). To the contrary, the determination made by the Attorney General in this case represents the official legal position of the Department of Justice and was set forth in a 1979 opinion of the Office of Legal Counsel (ER 304A). It warrants judicial deference. - 31 - considered construction of the Neutrality Act can only be overturned if it is deemed unreasonable. Committee for an Independent P-I V. Hearst Corp., 704 F.2d 467, 472-473 (9th Cir.), cert. denied, 104 S.Ct. 236 (1983). The responsibility to construe and enforce criminal statutes lies at the core of the executive's function, United States V. Dotterweich, 320 U.S. 277, 285 (1943), see p. 20-22, supra, and the principle of deference is particularly apt when the statutory construction affects the nation's foreign policy. See generally Dames & Moore V. Regan, 453 U.S. 654, 674-684 (1981); Haig V. Agee, 453 U.S. 280, 301-303 (1981). The Attorney General's resolution of the fundamental question in this case -- whether Congress intended to criminalize acts of Administration officials pursuing official foreign policy objectives -- ought not be questioned, therefore, absent complete unreasonableness or bad faith. As we show below, the Attorney General's position on the Neutrality Act is not only eminently reasonable, but compelled by considerations of the plain language of the statute, the circumstances surrounding its enactment, and the post-enactment history of executive and legislative measures consistent with that position. By its very terms, the statute proscribes individual conduct, not government activities. The statute today addresses " [w] hoever, within the United States, knowingly begins or sets on foot * * * any military or naval expedition or enterprise to be carried on from thence against the territory or dominion of any foreign prince or state * * *." 18 U.S.C. 960. The use of the term "whoever," like its statutory predecessor "any person, " 1 Stat. 381, 384 (1794), is no mere catch-all expression. At - 32 - common law, a statutory reference to "any person" or "whoever" did not include the sovereign if such an interpretation would impinge upon the sovereign's prerogatives, an understanding of which the colonists presumably were aware. See Street, Effect of Statutes Upon the Rights and Liabilities of the Crown, 7 U. Toronto L.J. 357 (1947). Congress presumptively does not intend to include official governmental action when including the open- ended phrase "any person. " That canon of statutory construction has continuing vitality today. In United States V. Cooper Corp., 312 U.S. 600 (1941), the Supreme Court addressed the issue whether "any person" in Section 7 of the Sherman Act included the United States. The Court declared that "in common usage, the term 'person' does not include the sovereign, [and that] statutes employing the phrase are ordinarily construed to exclude it."=Id. at 604. See also Wilson V. Omaha Indian Tribe, 442 U.S.E653, 667 (1979). Moreover, as the Court stated in FPC V. Tuscarora Indian Nation, 362 U.S. 99, 120 (1960), a "general statute imposing restrictions does not impose them upon the Government itself without a clear expression or implication to that effect." (quoting United States V. Wittek, 337 U.S. 346, 358-359 (1949)). The intent to preserve the gist of the common law rule seems clear. Cf. United States V. United Mine Workers, 330 U.S. 258, 272 (1947) (reaffirming the "old and well-known rule that statutes which in general terms divest pre-existing rights or privileges will not be applied to the sovereign without express words to that effect. "). The statutory rule takes on that much more force when combined with the familiar canon that criminal statutes are - 33 - strictly construed. In a criminal statute, then, it is logical to conclude that "person" does not apply to Administration officials carrying out governmental policy. Thus, by reference to traditional guides of statutory interpretation, the word "whoever" in the context of this criminal provision cannot bear the construction proffered by plaintiffs. "Whoever" reaches private conduct, not that authorized or initiated by official governmental policy. The Attorney General's interpretation on its face is thus 8 unquestionably reasonable. A. The Legislative History Clearly Demonstrates That The Neutrality Act Sought To Proscribe Private As Opposed To Official Governmental Involvement In The Affairs Of Foreign "Neutral" Nations. Examining the events leading up to enactment of the 1794 8 The district court stated that British antecedents to the Neutrality Act illuminate Congress' intent to circumscribe the executive's authority (ER 309-310). The court contended that since the earlier statutes provide exceptions for those acts "with leave or license of the crown," Congress' failure to adopt a similar qualifier in the Neutrality Act proves that the Act applies to official government policy (Id.) The court's reasoning is ill-conceived. To begin with, the section of the Neutrality Act in dispute had no direct British precursor. See C. Fenwick, The Neutrality Laws of the United States 27 (1913); Lobel, The Rise and Decline of the Neutrality Act: Sovereignty and Congressional War Powers in United States Foreign Policy, 24 Harv. Int'l L. J. 1, 32 n.164 (1983). Rather, the British statutes -- 12 Anne c.ll (1713); 9 George 2, c.30 (1736); 29 George 2, c.17 (1756) -- all concerned prohibiting British subjects from enlisting in foreign wars. Even without the clause "with leave or license of the crown," the statutes would not have restrained official acts of the executive, and the statutes' only impact on government officials was the de minimus restriction on their participation as individuals in a foreign war. Since the statutes in question have no relevance to the problem Congress attempted to remedy in Section 5 of the Neutrality Act, Congress could not have copied the statutes verbatim even if it had SC desired. - 34 - Neutrality Act removes any possible doubt as to the statute's purpose. Congress sought not to restrict executive prerogatives under Article II, but to support the executive by criminalizing acts of individuals that threatened to interfere with the government's conduct of foreign policy. President Washington feared that precipitous acts by individual citizens, primarily instances of privateering or of aid to privateering, would embroil the country in the war between France and England. Believing that open hostilities would jeopardize our newly won independence, President Washington opted for as strict a policy of neutrality as possible. C. Fenwick, supra, at 16-26. To that end, President Washington issued a proclamation of neutrality in April of 1793 warning citizens to avoid all acts which threatened to subvert the government's chosen neutral course. See 1 American State Papers, Foreign Relations 140 (1883). Despite the proclamation, French vessels continued to be armed and commissioned in American ports, and the celebrated French Minister, Edmond Charles Genet, asserted French jurisdiction over prizes brought into those ports. C. Fenwick, supra, at 18-20. President Washington consequently called upon Congress, as soon as it had reconvened, to enact legislation to ensure American neutrality: "Where individuals shall, within the United States, array themselves in hostility against any of the Powers at war * * * these offenses cannot receive too early and close an attention, and require prompt and decisive remedies. " 4 Annals of Congress 11 (1793). Congress responded by passing the Neutrality Act. Its purpose, as discussed on the House floor, was to strengthen the - 35 - hand of the President: "We have been told from the first authority- that of the PRESIDENT an authority which in no Government but ours would be called in question- that such additional powers were necessary. But if, after this notice, we reject the bill, this must dampen the exertions of the Executive; and what if we shall be driven into a war by the licentious behaviour of some individuals?" 4 Annals of Congress 743 (remarks of Rep. Ames). Far from circumscribing executive authority, the Neutrality Act was proposed by the executive to strengthen the 9 executive. The legislative history, therefore, contrary to the conclusory remarks of the district court (ER 311), 10 makes it 9 Circumstances surrounding the almost contemporaneous reenactment and revision of the Neutrality Act buttress the above conclusion. The Act was first amended substantively at President Adams' request in 1797, Act of March 2, 1797, ch. 5, 1 Stat. 497. The amendments tightened the proscription against privateering, and thereby girded the government's course of neutrality. C. Fenwick, supra, at 30-31. Twenty years later, in the wake of continued protests from Spain and Portugal, President Madison lobbied Congress for further amendments which resulted in the Act of March 3, 1817, ch. 58, strengthening the executive's hand against shipowners who lent their vessels. in aid of Latin American revolutionaries. See C. Fenwick, supra, at 35-39. Supplementary legislation was again passed in 1838, Act of March 10, 1838, 15 Stat. 212, this time to increase the executive's power against citizens aiding Canadians to overthrow British rule. See C. Fenwick, supra, at 42-43. The pattern has been consistent: neutrality laws have been proposed by the executive to bolster the central government's foreign policy. 10 The district court's glaring failure to address the legislative purpose behind enactment of the Neutrality Act is noteworthy. Instead of analyzing the circumstances giving rise to the Neutrality Act, it baldly asserted that [o]ne of [the Act's] major purposes was to protect the constitutional power of Congress to declare war or authorize private reprisals against foreign states" (ER 311), and cited only to the law review article of plaintiffs' counsel, Professor Lobel, supra note 8, for support. But ironically, even Professor Lobel elsewhere in the article concluded that: "The fundamental purpose of the (CONTINUED) - 36 - clear that Congress sought to fortify governmental control over foreign policy through enactment of the Neutrality Act. Nor does the one case relied upon by the district court, United States V. Smith, 27 F. Cas. 1192 (C.C.S.D.N.Y. 1806), undermine the above understanding of the Act. In Smith, the court held that the President's alleged prior knowledge and approbation of a private military expedition did not shield the defendant mercenaries from prosecution under the Act. Even presuming the correctness of the trial court's decision in Smith, that case not only involved a prosecution of private individuals as opposed to government officials, it also concerned an expedition launched for private motives as opposed to the instant one which is alleged to be part of official government policy. The district court's opinion attempted to elide the differences by claiming that the essence of Smith is the 1 proposition that the Neutrality Act reaches acts authorized by the President (ER 313). But the court's characterization of Smith is itself faulty. Smith involved only allegations that the President knew of or "winked" at the private expedition, not that he authorized it in any way. After all, it should be remembered that it was the executive which initiated the prosecution in the first place. Indeed, Judge Patterson specifically questioned defendants' counsel about the nature of the critical allegation 10 (FOOTNOTE CONTINUED) Neutrality Act, however, lay not in asserting state sovereignty with respect to other states but in strengthening the authority of the central government vis-a-vis its citizens * * *." Id. at 24. - 37 - in the case: "You state in the affidavit that it was done with the knowledge and approbation of the president, but is it stated in the affidavit that he authorized the fitting out of the expedition?" The attorney responded, "I conceive that it was not necessary, " and then he disavowed his intention to advance such a claim. The Trials of William S. Smith, and Samuel Ogden 66 (Thomas Lloyd, stenographer 1807) (excerpt attached to this brief). This case, however, unlike Smith, involves allegations of direct governmental involvement in the expedition; in fact, plaintiffs allege that the government was funding the insurgents, and that the CIA was to play a key role in training the insurgents, all as a part of official United States foreign policy (ER 6-12). Smith simply does not address whether the Neutrality Act reaches the conduct of public officials acting 11 pursuant to governmental objectives. = B. This Country's History Of Repeated Military Actions Against "Neutral" Nations Supports The Attorney General's Construction of the Neutrality Act. As the district court recognized (ER 311), presidents throughout this nation's history have exercised the broad discretion invested to them under the Constitution to introduce 11 To our knowledge, no subsequent judicial decision has addressed the issue implicated in this case. However, it should be noted that the Supreme Court, in distilling the significance of the Neutrality Act, has stated that "no nation can permit unauthorized acts of war within its territory in infraction of its sovereignty." United States V. The Three Friends, 166 U.S. 1, 52 (1897) (emphasis added). The Court recognized that the neutrality laws were enacted "in order to provide a comprehensive code in prevention of acts by individuals within our jurisdiction inconsistent with our own authority, as well as hostile to friendly powers. Id. at 53 (emphasis added). - 38 - troops into foreign nations without first obtaining a declaration of war. Needless to say, this background of over one hundred instances of engaging in or supporting hostilities in "neutral" nations, see Emerson, War Powers Legislation, 74 West Va. L. Rev. 53 (1971); Monaghan, Presidential War-Making, 50 B.U.L. Rev. 22, 26-27 (1970), is difficult to square with plaintiffs' construction of the Act. Presidents have acted both with and without subsequent Congressional authorization. Vietnam and Grenada are two recent examples of a phenomenon which has marked the nation's history. Still, Congress as a whole has never invoked the Neutrality Act to oppose executive action. To the contrary, on many occasions it has adopted the executive's chosen path and provided funding for further military actions. See Emerson, supra, at 73. The district court attempted to evader this inconsistencyir its position by stating that Congress must not have intendedithe Neutrality Act to apply to military operations conducted by regular U.S. troops (ER 313). Yet the district court as well as plaintiffs are at a loss to explain why the Congress which purportedly sought to protect its war powers under Article I, § 8, by enacting the Neutrality Act would ever have exempted the most expansive infringement of its powers conceivable -- the President's right to introduce troops into foreign nations without a Congressional declaration of war. Moreover, as a historical matter, presidents not only have dispatched regular United States troops without seeking prior Congressional approval, but from the 1811-1813 secret war against Spanish Florida, see A. Sofaer, War, Foreign Affairs and Constitutional - 39 - Power 291-317 (1976), to the Bay of Pigs invasion, they have lent 12 the government's support to paramilitary operations. Practice thus corresponds with the intent of the enacting Congress -- the Neutrality Act was meant to proscribe only the acts of individuals interfering with the course of official 13 governmental foreign policy. In dismissing the import of the continuing history of military and paramilitary expeditions, the district court chose to rely instead on post-enactment remarks of various presidents to demonstrate that the Act encompasses official governmental policy (ER 311). To be sure, former presidents have publicly remarked that the warmaking powers, as a constitutional matter, are vested solely in Congress. See, e.g., Statement of Pres. Van Buren (Dec. 3, 1838), reprinted in 3 Messages and Papers of the 12 We note that according to the Senate Select Committee to Study Governmental Operations with Respect to Intelligence Activities, S. Rep. No. 755, 94th Cong., 2d Sess. Book I, 120 (1975), the government has supported paramilitary efforts. on other occasions as well, most notably to the Committee, in Laos in the early 1960's, and in Guatemala in the 1950's. 13 Attorney General Jackson's 1940 opinion, 39 Op. Atty. Gen. 484, 494-96, is not to the contrary. Jackson construed not the Neutrality Act of 1794, but an amendment inserted in the midst of World War I which had no antecedent in the original Act. Act of June 15, 1917, § 503, 40 Stat. 217, 222. In pertinent part the section reads: "During a war in which the United States is a neutral nation, it shall be unlawful to send out of the jurisdiction of the United States any vessel built, armed, or equipped as a vessel of war * * *." Moreover, the legislative history suggests that Congress enacted the provision to conform the conduct of the government in this respect to accepted international principles of neutrality. See H.R. Rep. No. 30, 65th Cong., 1st Sess. 9 (1917). Unlike in 1794, the fear was not just that the acts of individuals could propel the nation into war, but that foreign powers would interpret official government conduct in such a way as to lead to war. - 40 - Presidents 487 (J. Richardson ed. 1896); statement of Pres. Buchanan, Cong. Globe, 35th Cong., 1st Sess. 217 (Jan. 7, 1858). By citing these speeches, the district court apparently wished to graft a constitutional perspective on Congress' hegemony over the warmaking powers, a jurisprudential view which is by no means universally shared, onto a criminal statute drafted by the Executive Branch which incontrovertibly sought to augment the central government's control over foreign policy. The speeches shed no light on the proper construction of the Neutrality Act. They do not refer to the Neutrality Act at all, and any possible significance is belied by the accompanying history of repeated military incursions into nations without a declaration of war. Similarly, the district court's reliance on Senator Slidell's attempt to amend the Neutrality Act in the 1850's is misplaced (ER 311-312). Slidell sought to amend the Neutrality Act to allow the President to suspend its operation whenever required "in the public interest." Cong. Globe, 33d Cong., 1st Sess. 1021-1024 (May 1, 1854). The purpose of his amendment was to enable southerners to invade Cuba in order to prevent the impending abolition of slavery by the Spanish Government. Id. at. 1021. We do not understand plaintiffs to suggest that Slidell's scheme could conceivably have enjoyed the official sanction of the government. Slidell's amendment was addressed not to official government initiatives, but to private ventures. By rebuffing Slidell's attempt, Congress merely reaffirmed that the President should not "wink" at private expeditions launched for private purposes. The efforts of Senator Slidell, like the remarks of - 41 - the former presidents, simply do not support plaintiffs' position that the Neutrality Act was ever thought to circumscribe the acts of federal officials implementing official government policy. C. Recent Congressional Enactments Are Inconsistent With Plaintiffs' Thesis That The Executive's Conduct Of Official Foreign Policy Could Conceivably Violate the Neutrality Act. In recent years, Congress and the executive have engaged in a continual dialogue over the executive's right to conduct so- termed covert activities as part of its foreign policy. Although the two branches have not always agreed, the debates themselves demonstrate that Congress has long been aware of the executive's conduct of such activities, and the disagreements which have arisen concern not whether the conduct is criminal, but whether the activities should be carried out with greater Congressional participation. In light of repeated Congressional measures- recognizing and authorizing appropriations for such actions the district court's conclusion that the official conduct of foreign policy may reasonably constitute a criminal violation is simply specious. In the aftermath of the Vietnam War, Congress as a whole asserted a greater role in foreign policy matters. In 1973, Congress enacted the War Powers Resolution, Pub. L. No. 93-148, 87 Stat. 555, which requires the President to consult with Congress and provide reports concerning the introduction of government troops abroad, 50 U.S.C. $ 1543. The only sanction provided, however, is that "[w]ithin sixty calendar days after a report is submitted * * * the President shall terminate any use of United States Armed Forces * * * unless [several specified - 42 - conditions are met] 50 U.S.C. $ 1544(b). Enactment of the Hughes-Ryan amendment one year later, Pub. L. No. 93-559, 88 Stat. 1804 (codified at 22 U.S.C. § 2422), manifests a similar response to executive conduct of foreign affairs, this time directly relating to covert operations. In placing procedural limitations on CIA covert activities, Congress unquestionably recognized the underlying exercise of executive power: "Notwithstanding this limitation, the President may authorize and direct that any operation in a foreign country be resumed, or that any other operation in a foreign country be initiated, and funds may be expended therefor, if but not before, he (1) finds that such operation is important to the national security * * * " S. Rep. No. 1299, 93d Cong., 2d Sess. 43 (1974) (emphasis added). Any questions concerning the legitimacy of the executive's exercise of that power were not resolved by criminalizing the executive's conduct. Bather, Congress treated the subject of the covert actions as falling within the domain of both the executive and Congress -- each had its assigned role. The Hughes-Ryan legislation would for the most part be superfluous if the Neutrality Act reached covert actions pursued as a part of official government policy. Congress has continued to help shape the executive's conduct 14 of covert activities. Indeed, Congress recently has authorized appropriations for the very activities which 14 Congress amended the Hughes-Ryan legislation in 1980, Pub. L. No. 96-450, 94 Stat. 1981 (codified at 50 U.S.C. § 413), providing for more extensive Congressional oversight of intelligence activities. - 43 - plaintiffs claim violate the neutrality laws. In passing the 1984 Intelligence Authorization Act on November 18, 1983, Congress affirmatively authorized funding should the executive choose to aid the insurgents in Nicaragua. The Act set a twenty- four million dollar cap on expenditures "for the purpose or which would have the effect of supporting, directly or indirectly, military or paramilitary operations in Nicaragua by any nation, group, organization, movement, or individual." Intelligence Authorization Act for Fiscal Year 1984, Pub. L. No. 98-215, § 108, 97 Stat. 1473. Contrary to the district court's statement that the funding is irrelevant (ER 320), the Congressional authorization is clearly inconsistent with plaintiffs' thesis that the activities charged constitute criminal violations. Thus, while Congress has chosen to place some limitations upon the executive's conduct of covert activities, including- providing aid for paramilitary groups, it has also recognized the legitimacy of the underlying exercise of executive authority. Congressional participation in that exercise undermines plaintiffs' argument that the Neutrality Act was designed to circumscribe the executive's foreign affairs prerogatives. The Attorney General has reasonably concluded that the President and senior Administration officials cannot conceivably have violated a federal criminal law by allegedly pursuing policies explicitly funded by Congress. III. THE NEUTRALITY ACT'S APPLICABILITY TO OFFICIAL ACTIONS OF THE EXECUTIVE BRANCH THAT HAVE BEEN SUPPORTED BY CONGRESS PRESENTS A NONJUSTICIABLE POLITICAL QUESTION Given Congress' , legislation funding the government's Nicaragua policy, this case presents a political question - 44 - inappropriate for judicial resolution. It is important to reemphasize the extraordinary relief that plaintiffs seek--a declaration that the government's official conduct of foreign policy may violate a criminal provision housed in the Neutrality Act. What they are seeking, then, is for this Court to intrude upon an area constitutionally entrusted to the other two branches. But, as the Supreme Court has stated: "the very nature of executive decisions as to foreign policy is political not judicial. Such decisions are wholly confided by our Constitution to the political departments of the government, Executive and Legislative. " Chicago & Southern Air Lines, Inc. V. Waterman Steamship Corp., 333 U.S. 103, 111 (1948). Measured against the standards articulated in Baker v. Carr, 369 U.S. 186, 217 (1962), the issue implicated in this case is nonjusticiable: Prominent on the surface of any case=held to involve a - political question is found a textually demonstrable constitutional commitment of the issue to a coordinate political department * * * or the impossibility of a court's undertaking independent resolution without expressing lack of the respect due coordinate branches of government; or an unusual need for unquestioning adherance to a political decision already made; or the potentiality of embarassment from multifarious pronouncements by various departments on one question. " First, there can be no question but that there is clearly a "textually demonstrable constitutional commitment of the issue to a coordinate political department." The conduct of foreign affairs in general, and the decision to provide covert aid in particular, lie within the prerogatives of Congress and the President. Recent legislation, see pages 42-44, supra, amply demonstrates that the two branches have joined in - 45 - continuing discourse to delineate their respective roles in so- termed covert aid decisions. As the Court of Appeals for the First Circuit held in dismissing a challenge to the conduct of the Vietnam War, [a]s to the power to conduct undeclared hostilities beyond emergency defense, then, we are inclined to believe that the Constitution in giving some essential powers to Congress and others to the executive, committed the matter to both branches, whose joint concord precludes the judiciary from measuring a specific executive action against any specific clause in isolation." Massachusetts V. Laird, 451 F.2d 26, 33 (lst Cir. 1971); see Sarnoff V. Connally, 457 F.2d 809 (9th Cir.) (dismissing challenge to Vietnam War on political question ground because "[t]he conduct of foreign affairs is within the exclusive province of Congress and the Executive. "), cert. denied, 409 U.S. 929 (1972). The district court's order disrupts the ongoing interplay between Congress and the 1" Executive on the extent of covert activities, distorting the balance envisioned in the Constitution. In face of the commitment to the other branches, plaintiffs should not be permitted to bypass those branches -- any redress should be obtained through the political process. Second, judicial intrusion into the President's realm of foreign policymaking can only end in denigrating the "respect due coordinate branches of government." The district court's order casts a pall upon the government's conduct of foreign policy, and it brings into question the legitimacy of past presidencies as well, since the majority of presidents have aided hostilities in "neutral" nations. - 46 - Finally, not only does the district court's order threaten to erode the respect due coordinate branches of government, but it exposes the government to the "real danger of embarassment from multifarious pronouncements by various departments on one question. " The Executive Branch has allegedly articulated its view as to the legitimacy of aid to the Nicaraguan insurgents, and Congress through appropriations has acquiesced in that determination. The judiciary simply has no role to play. Recognizing the propriety of that consideration, the Court of Appeals for the Fifth Circuit in Dickson V. Ford, 521 F.2d 234 (5th Cir. 1975), cert. denied, 424 U.S. 954 (1976), dismissed a challenge to the President's decision backed by Congress to provide foreign aid to Israel. The Court applied the political question doctrine because a determination that foreign aid was necessary was "a 'question uniquely demand[ing] single-voiced statement of the Government's views. Id. at 236. Since the Executive and Legislative Branches have already manifested their view that the Neutrality Act does not apply to the alleged governmental aid for Nicaraguan insurgents, the need for a "single voice" is just as pressing. The district court's pronouncement therefore may "rattle the delicate diplomatic balance that is required in the foreign affairs arena. " Sanchez- Espinoza V. Reagan, supra (dismissing challenge to alleged U.S. support of covert activity in Nicaragua on political question grounds). When the executive branch has pursued a foreign policy objective and received Congress' imprimatur, judicial intrusion is wholly inappropriate. - 47 - CONCLUSION For the foregoing reasons, this Court should reverse the district court's judgment. Respectfully submitted, RICHARD K. WILLARD Acting Assistant Attorney General JOSEPH P. RUSSONIELLO United States Attorney LEONARD SCHAITMAN JOHN F. CORDES HAROLD J. KRENT Attorneys, Civil Division-Appellate Staff, Room 3127 Department of Justice Washington, D.C. 20530 Telephone: FTS 633-4214 MARCH 1984 - 48 - STATEMENT OF RELATED CASES There are no related cases within the meaning of Local Rule 13(b)(4). . = 11 111 ÷ - - 49 - CERTIFICATE OF SERVICE I hereby certify that on this 20th day of March, 1984, I served the foregoing Brief for the Appellants by causing copies to be Express Mailed, postage prepaid, to: Ellen Yaroshefsky Michael D. Ratner Sarah Wunsch Peter Weiss Center for Constitutional Rights 853 Broadway New York, N.Y. 10003 Jules Lobel University of Pittsburgh Law School 3900 Forbes Ave. Law Building, Room 505 Pittsburgh, Pa. 15260 Marc Van der Hout National Lawyers Guild 3689 18th Street San Francisco, California 94110 30 F. CORDES = Cowe JOHN Attorney Civil Division, Room 3617 Department of Justice Washington, D.C. 20530 - 50 - ADDENDUM A -- Transcript Excerpt from Smith case B -- Ethics in Government Act, 28 U.S.C. §§ 591-598 C -- Neutrality Act, 18 U.S.C. § 960 THE ADDENDUM A TRIALS OF WILLIAM S. SMITH, AND SAMUEL G. OGDEN, FOR MISDEMEANOURS, HAD III THE CIRCUIT COURT OF THE UNITED STATES = THE NEW-YORK DISTRICT, IN=JULY, 1806. - WITH 4 PEELIMINARY ACCOUNT or THE PROCEEDINGS or THE- SAME COURT AGAINST MESSRS. SMITH & OGDEX, IN THE PRECEDING APRIL TERM. BY THOMAS LLOYD, STEN APHER. NEW-YCRK: PRINTED BY AND FOR I. RILEY AND CO. THE 1807. tries. But if the foreign power. shall itself have broken that approbat amity, and shall have given just grounds of war. no government must su ouglit to omit $ providing and preparing the means" for military WC dono enterprises nor could any Law have intended to prevent the pre- measure paratory efforts of individuals for subduing the public enemy- defendan The memorable congress that commenced your revolution did We a not hesitate to provide and prepare the means of meeting the mitigatio English before actual war was declared nor did it censure or it is only discountenance those patriots. who unauthorised by any orders ishment, and before the formal declaration of war, possessed themselves putting C of Ticonderoga and Crown Point. trary to The circumstances of the times, we have shown, justified the common president in giving his approbation. and my client, under that ap- matters probation, in providing and preparing the means of a military the of the iss terprise against Spain. And surely no enterprise could be more the fact C useful or effectual for drawing the enemy from our southern and judge, aft western frontiers: none more worthy of the exalted and philoso the cas phic mind of our chief magistrate; none more consonant to the prisonme enlightened and philosophic views of society and politics, which I verily b he has exhibited to the world. than an expedition to liberan case, tho South America: to destroy at once Spanish tyranny and power to be wo on our own continent to enfranchise. by one effort, millions of printed can our fellow creatures from the most frightful Londage ; and to br. because t the foundations. in SO large a portion of the globe, for the free- cant circi dom and the happiness of man ! allude 1 PATERSON, J. You state in the affidavit that it was done with P. 335. the knowledge and approbation of the president, but is it stated = sch the C the affidavit that he authorized the fitting out of the expedition? aggravati Einmet. I conceive it was not necessary : for though I have dictment argued upon the effects of an authorisation, it was only to show ing so:as that the argument of the adverse counsel went much too far. that the f when they contended that the president could not authorise any necessari such measure. For our defence, it will be only necessary tr se! to res show that the president was under the circumstances of the will find times. warranted to provide and prepare the means for a military aggravat expecition; and that in what he might do. me acted with is distinctic knowledge and approbation. Qui prohibere potent " NON pr. graration hibet, juiet. The knowledge and approbation of the ci.ief г.ш- in mitig. gistrate and heads of partments. if We shall prove them to have this disti been sufficiently express and positive, will amount to a justifies- have a ri tion; but even if Hi should f.il in establishing them to that 11. trary to tent, they. will still abord very powerful indus ements for nities Evidence ing the punishment. characte This is denied on the oder side: but I would ask, if it crain whent , be proved that this caterja 7. was carried on against the prev. But ti dent's express ender. would 1.01 that be matter a. gravation' must ha II it world. su.civ the reverse must be matter of midgries- very unl mistak.. inco WHAT :1 defendent may have been icd by the such a 03 SPECIAL PROSECUTOR 28 § 591 587. Salaries (2) any individual serving in a position listed in The Attorney General shall fix the annual sala- section 5312 of title 5; es of United States trustees and assistant United (3) any individual working in the Executive Lates trustees at rates of compensation not to Office of the President who is compensated at or aceed the lowest annual rate of basic pay in effect above a rate equivalent to level II of the Execu- or grade GS-16 of the General Schedule pre- tive Schedule under section 5313 of title 5; cribed under section 5332 of title 5. (4) any Assistant Attorney General and any Mided Pub.L. 95-598, Title II, § 224(a), Nov. 1978, 92 individual working in the Department of Justice Lat. 2664 compensated at a rate at or above level III of the Executive Schedule under section 5314 of title 5; 588. Expenses (5) the Director of Central Intelligence, the Necessary office expenses of the United States Deputy Director of Central Intelligence, and the rustee shall be allowed when authorized by the Commissioner of Internal Revenue; Attorney General. (6) any individual who held any office or posi- idded Pub.L. 95-598, Title II. $ 224(a), Nov. & 1978, 92 tion described in any of paragraphs (1) through 2664.) (5) of this subsection during the period consisting of the incumbency of the President such individu- 589. Staff and other employees al serves plus one year after such incumbency, The United States trustee may employ staff and but in no event longer than two years after the ther employees on approval of the Attorney Gen- individual leaves office; ral. (7) any individual described in paragraph (6) -dded Pub.L. 95-598, Title II, 224(a), Nov. 6, 1978, 92 who continues to hold office for not more than 90 tat. 2664.) days into the term of the next President during the period such individual serves plus one year after such individual leaves office; CHAPTER 39 -INDEPENDENT COUNSEL (8) the chairman and treasurer of the principal national campaign committee seeking the elec- -C. 91. Applicability of provisions of this chapter. tion or reelection of the President, and any offi- 2. Application for appointment of independent cer of the campaign exercising authority at the counsel. national level, such as the campaign manager or 3. Duties of the division of the court. director, during the incumbency of the President. + Authority and duties of independent counsel. 5. Reporting and congressional oversight. (c) Whenever the Attorney General receives in- 6. Removal of independent counsel: termination of formation sufficient to constitute grounds to inves- office. tigate that any person not described in subsection 7. Relationship with Department of Justice. (b) of this section has committed a violation of any 38. Termination of effect of chapter. Federal criminal law other than a violation constitu- Another chapter 39. set out preceding this chapter. comprises ting a petty offense, the Attorney General may tions 581 to 589 of this title. conduct an investigation and apply for an indepen- So in original dent counsel pursuant to the provisions of this Effective Date of Chapter. Section 604 of Pub.L. chapter if the Attorney General determines that -621 provided in part that this chapter shall take effect Oct. 26, 1978. investigation of such person by the Attorney Gen- eral or other officer of the Department of Justice 591. Applicability of provisions of this chap- may result in a personal. financial, or political conflict of interest. ter (a) The Attorney General shall conduct an inves- (Added Pub.L. 95-521, Title VI, 601(a), Oct. 26, 1978, 92 Stat. 1867, and amended Pub.L. 97-409, §§ 3, 4(a). Jan. 3. gation pursuant to the provisions of this chapter 1983, 96 Stat. 2039, 2040.) henever the Attorney General receives informa- on sufficient to constitute grounds to investigate Applicability to Specific Information Relating to that any of the persons described in subsection (b) Pending Proceedings this section has committed a violation of any Section 604 of Pub.L. 95-521 provided in part that the Federal criminal law other than a violation constitu- provisions of this chapter shall not apply to specific ting a petty offense. information received by the Attorney General pursuant to (b) The persons referred to in subsection (a) of section 591, if the Attorney General determines that- this section are- (1) such specific information is directly related to a prosecution pending at the time such specific informa- (1) the President and Vice President; tion is received by the Attorney General: Complete Annotation Materials, See Title 28 U.S.C.A. 407 28 § 591 DEPARTMENT OF JUSTICE Part (2) such specific information is related to a matter determining whether reasonable grounds exist which has been presented to a grand jury and is re- warrant further investigation or prosecution, t ceived by the Attorney General within 180 days of Attorney General shall comply with the written October 26, 1978; or other established policies of the Department (3) such specific information is related to an investi- gation that is pending at the time such specific informa- Justice with respect to the enforcement of crimin laws. tion is received by the Attorney General, and such specific information is received by the Attorney General (2) If- within 90 days of October 26, 1978. (A) after the filing of a memorandum und § 592. Application for appointment of a 1 inde- subsection (b) of this section, the Attorney Ge pendent counsel eral receives additional information sufficient 1 (a)(1) Upon receiving information that the Attor- constitute grounds to investigate about the ma ney General determines is sufficient to constitute ter to which such memorandum related, and grounds to investigate that any person covered by (B) the Attorney General determines, afte the Act has engaged in conduct described in sub- such additional investigation as the Attorne section (a) or (c) of section 591 of this title, the General deems appropriate, that reasonabl Attorney General shall conduct, for a period not to grounds exist to warrant further investigation o exceed ninety days, such preliminary investigation prosecution, of the matter as the Attorney General deems ap- then the Attorney General shall, no later that propriate. In determining whether grounds to in- ninety days after receiving such additional informa vestigate exist, the Attorney General shall con- tion, apply to the division of the court for the sider- appointment of I independent counsel. (A) the degree of specificity of the information received, and (d)(1) Any application under this chapter shal contain sufficient information to assist the divisior (B) the credibility of the source of the informa-- tion. of the court to select independent counsel and to define that independent counsel's prosecutorial (2) In conducting preliminary investigations pur- jurisdiction. suant to this section, the Attorney General shall have no authority to convene grand juries, plea (2) No application or any other documents, mate bargain, grant immunity, or issue subpenas. rials, or memorandums supplied to the division of (b)(1) If the Attorney General, upon completion the court under this chapter shall be revealed to of the preliminary investigation, finds there are no any individual outside the division of the court or reasonable grounds to believe that further investi- the Department of Justice without leave of the division of the court. gation or prosecution is warranted, the Attorney General shall so notify the division of the court (e) The Attorney General may ask a I indepen- specified in section 593(a) of this title, and the dent counsel to accept referral of a matter that division of the court shall have no power to appoint relates to a matter within that independent coun- a 1 independent counsel. sel's prosecutorial jurisdiction. (2) Such notification shall be by memorandum (f) The Attorney General's determination under containing a summary of the information received subsection (c) of this section to apply to the division and a summary of the results of any preliminary of the court for the appointment of a 1 independent investigation. counsel shall not be reviewable in any court. (3) Such memorandum shall not be revealed to (Added Pub.L. 95-521, Title VI, § 601(a), Oct. 26, 1978, 92 any individual outside the division of the court or Stat 1868, and amended Pub.L. 97-409, §§ 2(a)(1), the Department of Justice without leave of the 4(b)-(e), Jan. 3, 1983, 96 Stat. 2039-2041.) division of the court. So in original. (c)(1) If the Attorney General, upon completion References in Text. The Act, referred to in subsec. of the preliminary investigation, finds reasonable (a)(1), probably means the Ethics in Government Act of grounds to believe that further investigation or 1978 which enacted this chapter. For complete classifica- prosecution is warranted, or if ninety days elapse tion of that Act to the Code, see Short Title note under from the receipt of the information without 2 deter- section 701 of Title 2, The Congress and Tables volume. mination by the Attorney General that there are no reasonable grounds to believe that further investi- § 593. Duties of the division of the court gation or prosecution is warranted, then the Attor- (a) The division of the court to which this chapter ney General shall apply to the division of the court refers is the division established under section 49 for the appointment of a independent counsel. In of this title. Complete Annotation Materials, See Title 28 U.S.C.A. 408 39 SPECIAL PROSECUTOR 28 § 594 (b) Upon receipt of an application under section § 594. Authority and duties of a independent 92(c) of this title, the division of the court shall counsel ppoint an appropriate independent counsel and hall define that independent counsel's prosecutori- (a) Notwithstanding any other provision of law, jurisdiction. A 1 independent counsel's identity a 1 independent counsel appointed under this chap- nd prosecutorial jurisdiction shall be made public ter shall have, with respect to all matters in such request of the Attorney General or upon a independent counsel prosecutorial jurisdiction es- etermination of the division of the court that tablished under this chapter. full power and inde- isclosure of the identity and prosecutorial jurisdic- pendent authority to exercise all investigative and of such independent counsel would be in the prosecutorial functions and powers of the Depart- interests of justice. In any event the identity ment of Justice, the Attorney General, and any nd prosecutorial jurisdiction of such prosecutor hall be made public when any indictment is re- other officer or employee of the Department of urned or any criminal information is filed. Justice, except that the Attorney General shall exercise direction or control as to those matters (c) The division of the court, upon request of the Attorney General which may be incorporated in an that specifically require the Attorney General's pplication under this chapter, may expand the personal action under section 2516 of title 18. rosecutorial jurisdiction of an existing indepen- Such investigative and prosecutorial functions and counsel. and such expansion may be in lieu of powers shall include- he appointment of an additional independent coun- (1) conducting proceedings before grand juries and other investigations; (d) The division of the court may not appoint as (2) participating in court proceedings and en- ! independent counsel any person who holds or gaging in any litigation, including civil and crimi- ecently held any office of profit or trust under the Inited States. nal matters, that such independent counsel deems necessary; (e) If a vacancy in office arises by reason of the esignation or death of a 1 independent counsel, the (3) appealing any decision of a court in any livision of the court may appoint a independent case or proceeding in which such independent ounsel to complete the work of the independent counsel participates in an official capacity: ounsel whose resignation or death caused the va- (4) reviewing all documentary evidence availa- ancy. If a vacancy in office arises by reason of ble from any source; he removal of a independent counsel, the division (5) determining whether to contest the asser- the court may appoint an acting independent ounsel to serve until any judicial review of such tion of any testimonial privilege: emoval is completed. Upon the completion of (6) receiving appropriate national security uch judicial review. the division of the court shall clearances and, if necessary, contesting in court ake appropriate action. (including, where appropriate, participating in in (f) Upon a showing of good cause by the Attor- camera proceedings) any claim of privilege or General, the division of the court may grant a attempt to withhold evidence on grounds of na- ingle extension of the preliminary investigation tional security; onducted pursuant to section 592(a) of this title (7) making applications to any Federal court 2 period not to exceed sixty days. for a grant of immunity to any witness, consist- (g) Upon request by the subject of an investiga- ent with applicable statutory requirements, or on conducted by an independent counsel pursuant for -warrants, subpenas, or other court orders, this chapter, the division of the court may, in its and. for purposes of sections 6003, 6004, and scretion, award reimbursement for all or part of attorney's fees incurred by such subject during 6005 of title 18. exercising the authority vested uch investigation if- in a United States attorney or the Attorney Gen- (1) no indictment is brought against such sub- eral; ject: and (8) inspecting, obtaining, or using the original (2) the attorney's fees would not have been or a copy of any tax return. in accordance with incurred but for the requirements of this chap- the applicable statutes and regulations, and, for ter. purposes of section 6103 of the Internal Revenue .dded Pub.L. 95-521, Title VI, § 601(a), Oct. 26, 1978, 92 Code of 1954, and the regulations issued thereun- at 1869, and amended Pub.L. 97-409, §§ 2(a)(1), 5, Jan. der, exercising the powers vested in a United 1983, 96 Stat. 2039, 2041.) : So in original. States attorney or the Attorney General; So in original. Substitution of "counsel" for "prosecutor" was (9) initiating and conducting prosecutions in : made by Pub.L. 97-409. any court of competent jurisdiction, framing Complete Annotation Materials, See Title 28 U.S.C.A. 409 28 § 594 DEPARTMENT OF JUSTICE Part and signing indictments. filing informations. and References in Text Section 6103 of the Internal Rev handling all aspects of any case in the name of nue Code of 1954. referred to in subsec. (aM8), is classific the United States; and to Title 26. U.S.C.A., $ 6103. (10) consulting with the United States Attor- § 595. Reporting and congressional oversigl ney for the district in which the violation was alleged to have occurred. (a) A 1 independent counsel appointed under th chapter may make public from time to time, ar (b) A independent counsel appointed under this shall send to the Congress statements or reports C chapter shall receive compensation at a per diem the activities of such independent counsel. Thes rate equal to the annual rate of basic pay for level statements and reports shall contain such inform IV of the Executive Schedule under section 5315 of tion as such independent counsel deems appropi title 5. ate. (c) For the purposes of carrying out the duties of (b)(1) In addition to any reports made under sul the office of independent counsel, a independent section (2) of this section, and before the termin: counsel shall have power to appoint, fix the com- tion of a 1 independent counsel's office under se pensation, and assign the duties, of such employees tion 596(b) of this title, such independent couns as such independent counsel deems necessary (in- shall submit to the division of the court a repor cluding investigators, attorneys, and part-time con- under this subsection. sultants). The positions of all such employees are (2) A report under this subsection shall set fort exempted from the competitive service. No such fully and completely a description of the work C employee may be compensated at a rate exceeding the maximum rate provided for GS-18 of the Gen- the independent counsel, including the dispositio eral Schedule under section 5332 of title 5. of all cases brought, and the reasons for not pros cuting any matter within the prosecutorial jurisdi (d) A independent counsel may request assist- tion of such independent counsel which was no ance from the Department of Justice, and the De- prosecuted. partment of Justice shall provide that assistance.- (3) The division of the court may release to th which may include access to any records, files. or Congress. the public. or to any appropriate person other materials relevant to matters within such such portions of a report made under this subset independent counsel's prosecutorial jurisdiction, tion as the division deems appropriate. The div and the use of the resources and personnel neces- sion of the court shall make such orders as ar sary to perform such independent counsel's duties. appropriate to protect the rights of any individua (e) A ! independent counsel may ask the Attor- named in such report and to prevent undue inter ney General or the division of the court to refer ference with any pending prosecution. The div matters related to the independent counsel's prose- sion of the court may make any portion of a repor cutorial jurisdiction. A independent counsel's under this section available to any individual name may accept referral of a matter by the Attorney in such report for the purposes of receiving withi General. if the matter relates to a matter within a time limit set by the division of the court an such independent counsel's prosecutorial jurisdic- comments or factual information that such individ tion as established by the division of the court. If ual may submit. Such comments and factual infor such a referral is accepted, the independent counsel mation. in whole or in part, may in the discretion 0 shall notify the division of the court. such division be included as an appendix to suc (f) A ] independent counsel shall. except where report. not possible, comply with the written or other es- (c) A 1 independent counsel shall advise th tablished policies of the Department of Justice re- House of Representatives of any substantial an specting enforcement of the criminal laws. credible information which such independent cour (g) The independent counsel shall have full au- sel receives that may constitute grounds for a thority to dismiss matters within his prosecutorial impeachment. Nothing in this chapter or sectio jurisdiction without conducting an investigation or 49 of this title shall prevent the Congress or eithe at any subsequent time prior to prosecution if to do House thereof from obtaining information in th so would be consistent with the written or other course of an impeachment proceeding. established policies of the Department of Justice (d) The appropriate committees of the Congres with respect to the enforcement of criminal laws. shall have oversight jurisdiction with respect to th (Added Pub.L. 95-521, Title VI, § 601(a), Oct. 26, 1978, 92 official conduct of any independent counsel appoin Stat 1869, and amended Pub.L. 97-409, §§ 2(a)(1), ed under this chapter, and such independent cour 6(a)-(c), Jan. 3, 1983, 96 Stat. 2039, 2041.) sel shall have the duty to cooperate with the exe 1 So in original. cise of such oversight jurisdiction. Complete Annotation Materials, See Title 28 U.S.C.A. 410 Ch. 39 SPECIAL PROSECUTOR 28 § 597 (e) A majority of majority party members or a commenced before the division of the court and, if majority of all nonmajority party members of the such removal was based on error of law or fact, Committee on the Judiciary of either House of the may obtain reinstatement or other appropriate re- Congress may request in writing that the Attorney lief. The division of the court shall cause such an General apply for the appointment of a indepen- action to be in every way expedited. dent counsel. Not later than thirty days after the (b)(1) An office of independent counsel shall ter- receipt of such a request, or not later than fifteen minate when (A) the independent counsel notifies days after the completion of a preliminary investi- the Attorney General that the investigation of all gation of the matter with respect to which the request is made, whichever is later, the Attorney matters within the prosecutorial jurisdiction of General shall provide written notification of any such independent counsel or accepted by such inde- action the Attorney General has taken in response pendent counsel under section 594(e) of this title, to such request and, if no application has been and any resulting prosecutions, have been complet- made to the division of the court, why such applica- ed or so substantially completed that it would be tion was not made. Such written notification shall appropriate for the Department of Justice to com- be provided to the committee on which the persons plete such investigations and prosecutions and (B) making the request serve. and shall not be revealed the independent counsel files a report in full com- to any third party, except that the committee may, pliance with section 595(b) of this title. either on its own initiative or upon the request of (2) The division of the court, either on its own the Attorney General, make public such portion or motion or upon suggestion of the Attorney Gener- portions of such notification as will not in the al, may terminate an office of independent counsel committee's judgment prejudice the rights of any at any time, on the ground that the investigation of individual. all matters within the prosecutorial jurisdiction of (Added Pub.L. 95-521. Title VI. § 601(a), Oct. 26, 1978. 92 the independent counseLor accepted by such inde- Stat. 1871. and amended Pub.L. 97-409 § 2(a)(1), Jan. 3. pendent counsel under section 594(e) of this title, 1983. 97 Stat. 2039.) and any resulting prosecutions, have been complet- : So in original ed or SO substantially completed that it would be § 596. Removal of a independent counsel; appropriate for the Department of Justice to com- plete such investigations and prosecutions. At the termination of office time of termination, the independent counsel shall (a)(1) A 1 independent counsel appointed under file the report required by section 595(b) of this this chapter may be removed from office, other title. than by impeachment and conviction, only by the personal action of the Attorney General and only (Added Pub.L. 95-521, Title VI, § 601(a), Oct. 26, 1978. 92 Stat. 1872, and amended Pub.L. 97-409, §§ 2(a)(1), 6(d), for good cause, physical disability, mental incapaci- Jan. 3, 1983, 96 Stat. 2039, 2042.) ty, or any other condition that substantially impairs So in original. the performance of such independent counsel's duties. § 597. Relationship with Department of Jus- (2) If a 1 independent counsel is removed from tice office, the Attorney General shall promptly submit to the division of the court and the Committees on (a) Whenever a matter is in the prosecutorial the Judiciary of the Senate and the House of Rep- jurisdiction of a independent counsel or has been resentatives a report specifying the facts found accepted by a I independent counsel under section and the ultimate grounds for such removal. The 594(e) of this title, the Department of Justice, the committees shall make available to the public such Attorney General, and all other officers and em- report, except that each committee may, if neces- ployees of the Department of Justice shall suspend sary to protect the rights of any individual named all investigations and proceedings regarding such in the report or to prevent undue interference with matter, except to the extent required by section any pending prosecution, delete or postpone pub- 594(d) of this title, and except insofar as such lishing any or all of the report. The division of the independent counsel agrees in writing that such court may release any or all of such report in the investigation or proceedings may be continued by same manner as a report released under section the Department of Justice. 595(b)(3) of this title and under the same limitations (b) Nothing in this chapter shall prevent the At- as apply to the release of a report under that torney General or the Solicitor General from mak- section. ing a presentation as amicus curiae to any court as (3) A 1 independent counsel so removed may ob- to issues of law raised by any case or proceeding in tain judicial review of the removal in a civil action which a independent counsel participates in an Complete Annotation Materials, See Title 28 U.S.C.A. 411 28 § 597 DEPARTMENT OF JUSTICE Part 2 official capacity or any appeal of such a case or then pending matters before a : independent coun- proceeding. sel that in the judgment of such special counsel (Added PubL 95-521. Title VI. § 601(a). Oct. 26. 1978. 92 require such continuation until that independent Stat. 1872. and amended Pub.L. 97-409. § 2(a)(1)(A), Jan. counsel determines such matters have been com- 3. 1983. 96 Stat. 2039.) pleted. : So in original. (Added Pub.L. 95-521, Title VI. § 601(a). Oct. 26, 1978. 92 Stat. 1873. and amended Pub.L. 97-409. §§ 7. § 598. Termination of effect of chapter Jan. 3. 1983. 96 Stat. 2039. 2042.) : So in original This chapter shall cease to have effect five years References in Text. The date of enactment of the after the date of the enactment of the Ethics in Ethics in Government Act Amendments of 1982. referred Government Act Amendments of 1982, except that to in text. is the date of enactment of Pub.L. 97-409. this chapter shall continue in effect with respect to which was approved on Jan. 3. 1983. Complete Annotation Materials, See Title 28 U.S.C.A. 412 ADDENDUM C § 960. Expedition against friendly nation Whoever, within the United States, knowingly begins or sets on foot or provides or prepares a means for or furnishes the money for, or takes part in, any military or naval expedition or enterprise to be carried on from thence against the territory or dominion of any for- eign prince or state, or of any colony, district, or people with whom the United States is at peace. shall be fined not more than $3,000 or imprisoned not more than three years, or both. June 25, 1948, c. 645, 62 Stat. 745. Historical and Revision Notes Reviser's Note. Based on Title 18. U. Reference to territory or possessions of S.C.. 1940 ed., I 25 (Mar. 4, 1909 C. 321, $ the United States was omitted as covered 13. 35 Stat. 1090: June 15. 1917. C. 30, Ti- by definitive section 5 of this title. tie V. $8. 40 Stat. 223). Canal Zone. Applicability of section to Words "within the United States" were Canal Zone. see section 14 of this title. substituted for "within the jurisdiction" etc.. in view of the definition of United States in section 5 of this title.