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[JGR/Chadha re: District of Columbia] (7 of 12)
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[JGR/Chadha re: District of Columbia] (7 of 12)
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John Roberts' Subject Files
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Ronald Reagan Presidential Library Digital Library Collections This is a PDF of a folder from our textual collections. Collection: Roberts, John G.: Files Folder Title: [JGR/Chadha re: District of Columbia] (7) Box: 9 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/ 43 Box 9 - [JGR/Chadha re: District of Columbia] (7) - Roberts, John G.: Files SERIES I: Subject File THE WHITE HOUSE WASHINGTON November 21, 1983 MEMORANDUM FOR FRED F. FIELDING FROM: JOHN G. ROBERTS DDR SUBJECT: Your Suggested Change in Clarke/Rolark Letter Attached are two versions of the Clarke/Rolark letter, one with the change you suggested (modified slightly for grammatical purposes) and one without. I recommend the version without your suggested change. Stating that the Justice letter was "revised after we had the benefit of your views" suggests (1) that we have already evaluated and responded fully to their concerns, which is inconsistent with the last paragraph of our letter, and (2) that we were OK deeply involved in drafting the letter, a view we want to dispel rather than discourage. Attachments THE WHITE HOUSE WASHINGTON November 21, 1983 Dear Mr. Clarke and Ms. Rolark: Thank you for your letter of November 15, concerning a draft of a letter to Senator William V. Roth, Jr. from Assistant Attorney General Robert A. McConnell. That draft letter discussed H.R. 3932, a bill to amend the District of Columbia Self-Government and Governmental Reorganization Act to correct certain constitutional infirmities in the wake of the Supreme Court's recent decision in Immigration and Naturalization Service V. Chadha, 103 S.Ct. 2764 (1983). A letter from Assistant Attorney General McConnell concerning H.R. 3932 has now been sent, although with several changes from the draft you reviewed. I have referred your letter to Assistant Attorney General McConnell for his consideration and direct reply. The Department of Justice is most directly involved in these issues and accordingly is in the best position to respond to your expressed concerns. Thank you for sharing those concerns with us. Sincerely, Orig. signed by FFF Fred F. Fielding Counsel to the President The Honorable David A. Clarke The Honorable Wilhelmina J. Rolark Council of the District of Columbia Washington, D.C. 20004 FFF: JGR:aea 11/21/83 bcc: FFFielding/JGRoberts/Subj/Chron THE WHITE HOUSE WASHINGTON November 16, 1983 MEMORANDUM FOR ROBERT A. MCCONNELL ASSISTANT ATTORNEY GENERAL OFFICE OF LEGISLATIVE AFFAIRS FROM: FRED F. FIELDING Orig. signed by FFF COUNSEL TO THE PRESIDENT SUBJECT: D.C. Chadha Correspondence The attached letter from the D.C. Council Chairman and the Chairperson of the Council Judiciary Committee, together with a copy of my reply, is referred to you for your consideration and direct reply. I think it best to keep the debate on this matter, to the extent possible, between District officials and the Justice Department rather than District officials and the White House. CC: Michael Horowitz Counsel to the Director Office of Management and Budget FFF:JGR:aea 11/16/83 bcc: FFFielding/JGRoberts/Subj/Chron THE WHITE HOUSE WASHINGTON November 21, 1983 MEMORANDUM FOR FRED F. FIELDING FROM: JOHN G. ROBERTS DDR SUBJECT: Your Suggested Change in Clarke/Rolark Letter Attached are two versions of the Clarke/Rolark letter, one with the change you suggested (modified slightly for grammatical purposes) and one without. I recommend the version without your suggested change. Stating that the Justice letter was "revised after we had the benefit of your views" suggests (1) that we have already evaluated and responded fully to their concerns, which is inconsistent with the last paragraph of our letter, and (2) that we were deeply involved in drafting the letter, a view we want to dispel rather than discourage. Attachments THE WHITE HOUSE WASHINGTON November 21, 1983 Dear Mr. Clarke and Ms. Rolark: Thank you for your letter of November 15, concerning a draft of a letter to Senator William V. Roth, Jr. from Assistant Attorney General Robert A. McConnell. That draft letter discussed H.R. 3932, a bill to amend the District of Columbia Self-Government and Governmental Reorganization Act to correct certain constitutional infirmities in the wake of the Supreme Court's recent decision in Immigration and Naturalization Service V. Chadha, 103 S.Ct. 2764 (1983) A letter from Assistant Attorney General McConnell concerning H.R. 3932 has now been sent. That letter contains several changes from the draft you reviewed, and was revised after we had the benefit of your views. I have referred your letter to Assistant Attorney General McConnell for his consideration and direct reply. The Department of Justice is most directly involved in these issues and accordingly is in the best position to respond to your expressed concerns. Thank you for sharing those concerns with us. Sincerely, Fred F. Fielding Counsel to the President The Honorable David A. Clarke The Honorable Wilhelmina J. Rolark Council of the District of Columbia Washington, D.C. 20004 FFF: JGR:aea 11/21/83 bcc: FFFielding/JGRoberts/Subj/Chron THE WHITE HOUSE WASHINGTON November 21, 1983 Dear Mr. Clarke and Ms. Rolark: Thank you for your letter of November 15, concerning a draft of a letter to Senator William V. Roth, Jr. from Assistant Attorney General Robert A. McConnell. That draft letter discussed H.R. 3932, a bill to amend the District of Columbia Self-Government and Governmental Reorganization Act to correct certain constitutional infirmities in the wake of the Supreme Court's recent decision in Immigration and Naturalization Service V. Chadha, 103 S.Ct. 2764 (1983). A letter from Assistant Attorney General McConnell concerning H.R. 3932 has now been sent, although with several changes from the draft you reviewed. I have referred your letter to Assistant Attorney General McConnell for his consideration and direct reply. The Department of Justice is most directly involved in these issues and accordingly is in the best position to respond to your expressed concerns. Thank you for sharing those concerns with us. Sincerely, Fred F. Fielding Counsel to the President The Honorable David A. Clarke The Honorable Wilhelmina J. Rolark Council of the District of Columbia Washington, D.C. 20004 FFF:JGR:aea 11/21/83 bcc: FFFielding/JGRoberts/Subj/Chron THE WHITE HOUSE WASHINGTON ann November 16, 1983 Dear Mr. Clarke and Ms. Rolark: Thank you for your letter of November 15, concerning a draft of a letter to Senator William V. Roth, Jr. from Assistant Attorney General Robert A. McConnell. That draft letter discussed H.R. 3932, a bill to amend the District of Columbia Self-Government and Governmental Reorganization Act to correct certain constitutional infirmities in the wake of the Supreme Court's recent decision in Immigration and Naturalization Service V. Chadha, 103 S.Ct. 2764 (1983). A letter from Assistant Attorney General McConnell concerning H.R. 3932 has now been sent, although with several changes, from the draft you reviewed and revind apr we had the been 2 of your 1 I have referred your letter to Assistant Attorney General McConnell for his consideration and direct reply. The Department of Justice is most directly involved in these issues and accordingly is in the best position to respond to your expressed concerns. Thank you for sharing those concerns with us. Sincerely, Fred F. Fielding Counsel to the President Mr. David A. Clarke Ms. Wilhelmina J. Rolark Council of the District of Columbia Washington, D.C. 20004 THE WHITE HOUSE WASHINGTON November 16, 1983 MEMORANDUM FOR FRED F. FIELDING FROM: JOHN G. ROBERTS SUBJECT: D.C. Chadha Correspondence David Clarke, Chairman of the D.C. Council, and Wilhelmina Rolark, Chairperson of the Council's Committee on the Judiciary, have written you in response to the draft letter from Robert McConnell on H.R. 3932, the D.C. Chadha bill. As you know, OMB provided the Council with a copy of the draft for comment. The letter itself was sent out early this morning, with the changes we discussed yesterday. The letter contends that our position entails "disastrous consequences" for Home Rule, and would impede the ability of the Council to enact appropriate criminal laws to protect the citizens of the District. The letter reviews actions of the Council with respect to criminal law, in an effort to mount an argument that our fears of laxness are unjustified. The letter also notes that Congress, unlike the Council, is likely to ignore local District criminal law problems. Briefly, the answers: Our proposal does not have "disastrous consequences" for Home Rule. This bill is not, in the first place, a Home Rule bill at all but a bill to correct constitutional problems pointed out by Chadha. We support giving the Council plenary authority in every area except criminal law. Such an approach continues a distinction in current law permitting easier Congressional review of Council actions in the criminal law area. As to what the Council has done in the criminal area, there is some good and some bad. Our U.S. Attorneys Office, however, which deals with these issues on a day-to-day basis, advised us that zany ideas have been blocked only because of the threat of Congressional veto. The U.S. Attorneys Office was horrified at the prospect of the Council legislating in this area without the check of effective Congressional control. Finally, the Council can still act in this area. The fear that Congress will have to become intimately involved in the minutiae of local law is unfounded. All that the Council need do is obtain approval of its actions, which should be forthcoming for reasonable proposals. I do not think you should send a substantive reply to Clark and Rolark. The letter they're concerned about was from McConnell; their reply should be directed to him. This approach will help keep the dispute between the District and Justice, rather than the District and the White House, to the extent that is possible in light of OMB's "leaks" to District officials. A brief reply noting you have referred the letter to Justice for consideration and response is attached. I have copied Horowitz to let him know we think the matter should be kept over at Justice. Attachment THE WHITE HOUSE WASHINGTON November 16, 1983 Dear Mr. Clarke and Ms. Rolark: Thank you for your letter of November 15, concerning a draft of a letter to Senator William V. Roth, Jr. from Assistant Attorney General Robert A. McConnell. That draft letter discussed H.R. 3932, a bill to amend the District of Columbia Self-Government and Governmental Reorganization Act to correct certain constitutional infirmities in the wake of the Supreme Court's recent decision in Immigration and Naturalization Service V. Chadha, 103 S. Ct. 2764 (1983) A letter from Assistant Attorney General McConnell concerning H.R. 3932 has now been sent, although with several changes from the draft you reviewed. I have referred your letter to Assistant Attorney General McConnell for his consideration and direct reply. The Department of Justice is most directly involved in these issues and accordingly is in the best position to respond to your expressed concerns. Thank you for sharing those concerns with us. Sincerely, Fred F. Fielding Counsel to the President Mr. David A. Clarke Ms. Wilhelmina J. Rolark Council of the District of Columbia Washington, D.C. 20004 FFF:JGR:aea 11/16/83 bcc: FFFielding/JGRoberts/Subj/Chron THE WHITE HOUSE WASHINGTON November 16, 1983 MEMORANDUM FOR ROBERT A. MCCONNELL ASSISTANT ATTORNEY GENERAL OFFICE OF LEGISLATIVE AFFAIRS FROM: FRED F. FIELDING COUNSEL TO THE PRESIDENT SUBJECT: D.C. Chadha Correspondence The attached letter from the D.C. Council Chairman and the Chairperson of the Council Judiciary Committee, together with a copy of my reply, is referred to you for your consideration and direct reply. I think it best to keep the debate on this matter, to the extent possible, between District officials and the Justice Department rather than District officials and the White House. CC: Michael Horowitz Counsel to the Director Office of Management and Budget FFF: JGR:aea 11/16/83 bcc: FFFielding/JGRoberts/Subj/Chron ID # CU WHITE HOUSE CORRESPONDENCE TRACKING WORKSHEET O - OUTGOING ASH H INTERNAL R I - INCOMING Date Correspondence Received (YY/MM/DD) / 1 Name of Correspondent: David A. Clarke / Wilhelmina Rolask MI Mail Report User Codes: (A) (B) (C) Subject: Support of DC Home Rule ROUTE TO: ACTION DISPOSITION Tracking Type Completion Action Date of Date Office/Agency (Staff Name) Code YY/MM/DD Response Code YY/MM/DD CUHOLL ORIGINATOR 83,11,16 / Referral Note: WAT 18 D 83111116 5 83,11 17 Referral Note: / / Referral Note: / # Referral Note: / / / Referral Note: ACTION CODES: DISPOSITION CODES: A Appropriate Action % Info Copy Only/No Action Necessary A Answered C Completed CC - Comment/Recommendation R Direct Reply w/Copy B- - Non-Special Referral S Suspended D Draft Response S For Signature F Furnish Fact Sheet Tax -Interim Reply to be used as Enclosure FOR OUTGOING CORRESPONDENCE: Type of Response = -Initials of Signer Code = "A" Completion Date = Date of Outgoing Comments: Keep this worksheet attached to the original incoming letter. Send all routing updates to Central Reference (Room 75, OEOB). Always return completed correspondence record to Central Files. Refer questions about the correspondence tracking system to Central Reference, ext. 2590. 5/81 LETTER OF TRANSMITTAL HOUSE OF REPRESENTATIVES, COMMITTEE ON THE DISTRICT OF COLUMBIA, Washington, D.C., December 5, 1978. Mr. DAVID A. CLARKE, Esq., Chairman, Counsel on Judiciary, District of Columbia City Council, Washington, D.C. DEAR MR. CLARKE: The accompanying report contains the joint rec- ommendations of the House District Subcommittee on Judiciary and the Senate Subcommittee on Governmental Efficiency and the District of Columbia regarding the Law Revision Commission's proposed Basic Criminal Code. This joint report highlights the major deficiencies and problem areas in the Commission's code proposals, and suggests methods or alterna- tives for correcting them. In some instances, the report comments on certain minor or nonsubstantive technical problems which need to be addressed in order to make the LRC proposals a more workable and less ambiguous code. Each subcommittee has independently completed an extensive and thorough review and analysis of the hearings, statements, and pro- mission's proposed Basic Criminal Code. The joint report Bets forth posals compiled as a result of subcommittee considerations of the Com- recommendations, changes and amendments to the LRC proposals which both Subcommittees have identified as being in need of revision. There are numerous other issues on which the subcommittees will com- ment separately at a later date. The revision of the District of Columbia Criminal Code has been a tedious and careful process and has resulted in a voluminous and de- tailed work product by the Law Revision Commission and the House and Senate subcommittees. Their combined efforts have culminated in a comprehensive and modern set of criminal laws for the District of Columbia. The present criminal law of the District of Columbia is an outdated relic of mosaic statutes, cases, and administrative interpretations passed into law, in a piecemeal fashion, over a period of time that stretches from 1901 to the present. Time has changed the social mores and standards by which we live today. The criminal laws of the Dis- trict have not kept pace with that change. With the proposals made by the Law Revision Commission and the extensive hearings record and recommendations from the subcommittees, the City Council will stand in the unique position of being able to begin the modernization process without further delay. In the spirit of home rule, we are delighted to begin the process of transferring jurisdiction of the proposed criminal code to the City 3 VI Council 80 that they can complete the task of codification by adding the essential ingredient of their knowledge of the District of Columbia. We look forward to continued oversight, communication and exchange between Congress and the Council relative to the code, and to rapid progress towards completion of the task that we have begun. Respectfully submitted, THOMAS F. EAGLETON, Chairman, Senate Subcommittee on Governmental Efficiency. ROMANO L. MAZZOLI, Chairman, House Subcommittee on Judiciary. C.S.STAB STAB Guide to Proposed Reforms 8:1 THE,OFF OFFICIAL T JOURNA as OR THE DISTRICT OF COLUMBIA BAR EMBER SEPTEMBER OCTOBER 981 THE BALLOT BOX AND THE SUPREME COURT THE BAR'S RESPONSE TO LAWYER ALCOHOLISM ONG TOA A H 7d 964643 C MS ANTIF M MEISTER 1303 MADISON STREET NW WASHINGTON, DC 20011 TYE D.C. Crime Reform Proposed Guide to CRIME: CUTTING NAME BY DAVID A. CLARKE AND of crime; lawbreaking is not unrelated make recommendations for reform of ANNE MEISTER to problems in housing, education, rec- the local laws. Specifically, the com- reational resources or unemployment. mission was required to: A contribution can be made by legis- lative reforms, provided the reforms give special consideration to the are reasoned and address the aspects examination of the common law and of the crime problem that can be reme- statutes relating to the criminal law in died, in part, by changes in the lan- the District of Columbia, and all relevant guage of the law. Reforms also must judicial decisions, for the purpose of dis- covering defects and anachronisms in be designed to meet evolving commu- the law relating to the criminal law in the nity concerns and community values. District of Columbia and recommending To quote Roscoe Pound: "The law needed reforms.¹ must be stable, but it must not stand still." This article discusses the history of This task was tremendous because local criminal law reform, the legisla- the commission faced a body of crimi tive process for such reforms, and the nal law that had not been comprehen- measures introduced before the Coun- sively reviewed or revised since 1901. cil of the District of Columbia to make In 1975, the commission received par- reforms in the District's criminal laws. tial funding, and in 1976 the two-year ban on Council action in this area was extended for an additional two years. History of Local The commission focused its atten- tion on criminal law reform and Criminal Law Reform developed final recommendations for a revised "basic" criminal code for the Like many aspects of this city's his- District of Columbia by March 1978. tory, the history of local criminal law These recommendations were char- reform in the District of Columbia is acterized as a "basic" criminal code unusual. Even with the establishment since the recommendations proposed of a limited home rule government in made revisions in laws treating tradi- 1975, Congress reserved exclusive tional crimes against persons and pro- jurisdiction over revisions to the crimi- perty, such as murder, rape, robbery, nal law titles of the District of Colum- theft and arson, but did not address so- bia Code. It was not until 1979 that pri- called crimes against society, such as mary legislative jurisdiction over the prostitution, gambling and drug local criminal laws was transferred to offenses. In the areas considered, the the Council of the District of Columbia, commission recommended sweeping as the locally elected legislative body. changes in the substantive law and When Congress enacted the District provided a presumptive sentencing of Columbia Self-Government and model for these sentences it proposed Crime is an issue that touches all of us. Governmental Reorganization Act to to recodify, leaving the existing inde- In the District of Columbia, as in many provide for an elected local govern- terminate sentencing model for the urban jurisdictions, the problem of ment, the newly created government remaining offenses. crime is a reality of everyday life and was prohibited from enacting legisla- Congress held a series of hearings on 'fear of crime has reached alarming tion in a number of important areas these recommendations, but ultimately proportions. In response to this rising (D.C. Code, sec. 1-147(a)(9)(Supp. V determined to allow the council to concern about crime, the D.C. City 1978)). Included in the restrictions was complete the task. As a result of this Council has given serious considera- a two-year ban upon Council enact- transfer, the Criminal Code Project tion to many suggested reforms to our ment of any legislation with respect to was created as a special unit of the local criminal laws. Proposals have title 22 of the District of Columbia D.C. Committee on the Judiciary, been introduced to make changes in Code, relating to crimes; title 23, relat- designed to assist in the committee's the District's laws that deal with ing to criminal procedure; and title 24, review of criminal law legislation. Fol- drugs, sexual assault, prostitution, relating to prisoners and their treat- lowing this transfer of authority, the theft, white-collar crime, and sentenc- ment. During the period between the commission's recommendations were Illustration by Michael David Brown ing, among others. Yet none of the 1973 passage of the Home Rule Act introduced as the starting point for suggested reforms, either alone or in and the scheduled expiration of this local debate on these issues. The Com- combination, offers a complete solu- limitation on the new government's mittee on the Judiciary scheduled an tion to the problem. There is no single power, Congress enacted the District unprecedented series of eight public solution because there is no one cause of Columbia Law Revision Commis- hearings on the proposal. sion Act (D.C. Code, sec. 49-401 to At the hearings little testimony was Councilmember David A. Clarke, who repre- 403 (Supp. V 1978)). This act created a presented that expressed overall sup- sents Ward 1, is Chairperson of the Committee on the Judiciary of the Council of the District of prestigious advisory commission, with port of the commission's recommenda- Columbia. Anne Meister is the former Director members appointed by a variety of fed- tions, apart from that presented by the of the Criminal Code Project. eral and local sources, to examine and commission itself. Opponents of the Sentember/October 1981 Volume 6 Number 1 27 commission's proposal included the held on June 2, 1981. As described in approval resolution. However, acts U.S. Attorney for the District of the following section, these bills are at that seek to amend the criminal law Columbia, the executive branch of the various stages of the local legislative titles of the District of Columbia Code D.C. government, the Board of Judges process. are subject to disapproval by either and the Advisory Committee on Crimi- house of Congress. If an act is not dis- nal Rules of the D.C. Superior Court. approved within thirty legislative days Opposition to the proposal centered Legislative Process (not calendar days), it becomes law. around four major concerns: (1) the An alternative procedure for the en- practical obstacles of operating a dual For Local actment of legislation is the initiative system in which some, but not all, process, by which proposed legislation criminal offenses were recodified; (2) Criminal Law Reform is submitted to District voters in sum- the difficulty of understanding and mary form as an initiative measure. If The legislative process for local applying the new terminology used in approved by a majority of the regis- criminal law reform is somewhat un- the proposal, especially the new, tered, qualified electors voting on the usual. Congressional review of acts to uniform state of mind definitions used; measure, the initiative is sent to Con- amend the criminal law titles of the (3) the relative benefit of the proposed gress for review. District of Columbia Code, titles 22, 23 revision when weighed against the The twelve criminal law reform pro- and 24, differs from the review accord- costs of its implementation; and (4) the posals that will be discussed in this ed to other legislative measures. In all potential cost of the proposal, article are at various stages of the local other respects, the legislative process estimated at $132.6 million in added legislative process. One of these pro- is the same. capital and operating costs during the posals, the D.C. Uniform Controlled Once a bill has been introduced and Substances Act of 1981, recently first five years. referred to one of the nine standing became law. Another, the D.C. Sexual In June 1980, the Committee on the committees of the Council, (criminal Assault Reform Act of 1981, is under- Judiciary issued an interim report on law legislation is referred to the Com- criminal law reform in which the com- going congressional review and may mittee on the Judiciary), a public hear- mittee determined not to enact the have become law by the date of this ing may be scheduled. Notices of all Law Revision Commission's proposal. publication. A third proposal, the D.C. public hearings are published in the Bail Amendment Act of 1981, was dis- Rather, the committee decided to D.C. Register at least fifteen days in direct its resources toward the devel- approved by the Committee on the advance of the date of the hearing. Judiciary, but the Control of Prostitu- opment of legislation in areas specifi- The chairperson of the committee is cally identified during the course of the tion and Sale of Drugs in Public Places generally responsible for setting the Criminal Control Act of 1981 was hearings as posing special problems to agenda of that committee. If the com- or of particular interest to the commu- approved and is awaiting review by the mittee takes o'action on a bill, the bill nity. Some of these areas were includ- full Council. The remaining proposals dies at the expiration of the Council ed in the commission's proposal and are pending action by the Committee period. If a bill is placed on the agenda on the Judiciary. some were not. of the committee, following staff Consequently, the committee set as research and review of the comments priority reform of local laws, such as received, the committee members drug laws and white-collar laws, which meet to mark up the bill. At mark-up, Drug Reform do not provide an adequate basis for amendments may be made by the com- local law enforcement in the event of a mittee members and a formal vote is The District of Columbia Uniform transfer to District officials of prosecu- taken to approve or disapprove the Controlled Substances Act of 1981 tion authority. The committee also set measure. If approved, the final version became law on August 5, 1981. Pat- as priority the consideration of matters of the committee action on the bill is terned after the model developed by that were identified during the course called the committee print and this the National Conference of Commis- of the hearings as areas of pressing committee print, along with a report sioners on Uniform States Laws and, community concern, such as reform of detailing the purpose and impact of the to a certain extent, the current federal the sexual assault laws, drug laws, bill, is sent to the full Council for law, this legislation makes sweeping penalties for weapons offenses, bail review. reforms in the local drug laws. Prior laws and problems raised by juvenile The Council passes a bill (as opposed District law in this area consisted pri- crime. Over the next several months, to an emergency act, a budget request marily of the 1938 Uniform Narcotics the work of the Criminal Code Project act or a resolution) by voting twice to Drug Act, D.C. Code, sec. 33-401 to concentrated on drafting proposed leg- approve the measure in substantially 425, and the 1956 Dangerous Drug islation in many of these areas. the same form. Once passed. the bill is Act for the District of Columbia, D.C. This year. eleven bills have been sent to the Mayor. who may approve Code, sec. 33-701 to 712. These prior introduced to reform criminal law in or veto the measure. If vetoed by the laws lacked.clarity in defining those the District of Columbia. These bills Mayor, the measure still may be enact- substances placed under control and became the subject of another series of ed by a two-thirds majority vote of the penalized all first-time drug offenses public hearings on criminal law reform Council. Once a bill has been approved as misdemeanors, regardless of the held by the Committee on the Judici- by the Mayor or the Mayor's veto has substance involved, the type of con- ary on March 12 and 13, 1981. Just been overridden, the bill becomes an duct engaged in and the parties to the prior to these hearings, a twelfth crimi- act and is sent to Congress for review. illegal transaction. In addition, these nal law reform bill was introduced and Generally, Congress may disapprove prior laws did not address adequately an additional hearing on this bill was an act only by passing a joint dis- the diversion of drugs into illicit chan- 28 District Lawyer nels and used a cumbersome and time- term of imprisonment that may be controls. These provisions will serve to consuming method for updating the list imposed. Special penalties also are identify those persons in the District of of substances subject to control. As a provided for persons who are twenty- Columbia who have legitimate access result of these inadequacies, major drug one years of age or older who distrib- to controlled substances and to docu- cases in the District of Columbia gener- ute controlled substances to a minor or ment the movement of controlled sub- ally were prosecuted by the U.S. Attor- enlist the assistance of a minor to sell stances in the District. Other adminis- ney in the federal court system, rather or distribute controlled substances for trative reforms include a substantial than in the D.C. Superior Court. Conse- the benefit of the adult. Paralleling the expansion of the forfeiture powers of quently, the local preventive detention provisions of the current federal law, the District of Columbia, delineation of laws were not applicable to these cases. the new local drug law also penalizes more specific standards for the issu- In contrast, the District of Columbia persons who attempt or conspire to ance and implementation of adminis- Uniform Controlled Substances Act commit a controlled substances trative search warrants, and a provi- of 1981 creates a comprehensive sys- offense and permits conditional dis- sion for the admissibility of chemist tem governing the use of controlled charge of first offenders found guilty reports without a personal appearance substances in the District. It clearly of simple possession for personal use. by the chemist if the results of the identifies those substances subject to The District of Columbia Uniform analysis are not in dispute. Finally, the control and significantly expands the Controlled Substances Act of 1981 also new drug law authorizes the Mayor to coverage of the law by controlling all substances, excluding alcohol and tobacco, with a known potential for abuse. Depending upon factors such as the degree of abuse potential, the known effect, harmfulness and level of accepted medical use, each con- trolled substance is placed into one of five schedules. The highest schedule, Schedule I, contains substances that have a high potential for abuse and no accepted or safe medical use in treat- ment. The remaining schedules, II through V, control substances that have an accepted medical use but, in varying degrees, a lesser potential for abuse and for physical or psychic effects on users. The new drug law also creates an administrative system for scheduling new substances and re- scheduling those substances already subject to control. The use of an administrative system, rather than the regular legislative process, is designed to enable the District gov- ernment to react promptly to the introduction of new drugs and to changes in the known abuse potential of existing substances. Penalties under the new drug law, which are generally much higher than creates a new, closed regulatory sys- develop a series of educational pro- those provided under the prior local tem for the legitimate handling of con- grams for adult and juvenile violators laws, vary according to the gravity of trolled substances, in order to control about the dangers of drug use and the offense committed and the sched- better the diversion of these sub- abuse. ule of the substance involved. While stances to illicit sources. This regula- simple possession for one's own use tory system requires registration of all continues to be sanctioned as a misde- persons who wish to dispense, distrib- Sexual Assault Reform meanor offense, penalties for the man- ute, manufacture or conduct research ufacture, distribution, or possession with controlled substances in the Dis- The District of Columbia Sexual with intent to manufacture or distrib- trict of Columbia; sets requirements Assault Reform Act of 1981 was enact- ute range from up to one year impris- related to the recordkeeping, inventor- ed by the Council on July 14, 1981, onment and a $10,000 fine for schedule ies, order forms and prescriptions of signed by the Mayor on July 21, 1981, V substances, to up to fifteen years registrants; restricts the distribution and currently is undergoing congres- imprisonment and a $100,000 fine for and dispensing of controlled sub- sional review. Patterned after the pro- schedule 1 or II narcotics. Special pen- stances by registrants; and imposes posal developed by the D.C. Law Re- alties are provided for repeat offenders separate penalties for offenses com- vision Commission on sexual assault that double the maximum fine and mitted in violation of these regulatory. offenses, this legislation seeks to con- September/October 1981 Volume 6 Number 1 29 As amended in committee, this bill would revise the solicitation for the purposes of prostitution statute, D.C. Code, Sec. 22-2701, by raising the fine from $250 to $300, and by clarify- ing that the prohibition against solicit- ing acts of prostitution includes the specific, enumerated acts contained in the bill when engaged in for the pur- pose of prostitution. This bill also would revise the peddling of drugs on streets statute, D.C. Code, sec. 2-617, to clarify that these same specific enu- merated acts, when engaged in for the purpose of selling controlled sub- stances, are included in the prohibi- tion against offering for sale by ped- dling. The specific acts are described in the bill as follows: "remaining or wandering about a public place and repeatedly beckoning to, or repeated- ly stopping, or repeatedly attempting to stop, or repeatedly attempting to engage passers-by in conversation, or solidate and modernize local law in As originally proposed, the District repeatedly stopping or attempting to this area. Key provisions of this act of Columbia Sexual Assault Reform stop motor vehicles, or repeatedly would: Act of 1981 would have replaced this interfering with the free passage of (1) eliminate all gender-based refer- gender-based classification with a other persons." ences in sexual assault crimes; classification based upon age differ- (2) increase the protections afforded to ences between the two parties, pat- terning the law after a model used, in Theft and children who are wards by expanding the existing prohibition against sexual part, in thirty-four jurisdictions and recommended by the D.C. Law Revi- White-Collar Crimes activity by blood relations to apply also to adoptive parents, stepparents, cer- sion Commission. The prohibitions The Theft and White-Collar Crime tain relatives related by marriage, and against sexual activity with an older Act of 1981 is another major piece of other persons who live in the same or younger child contained in the bill household and who misuse their super- proposed legislation. This bill con- would apply even if the sexual activity visory or disciplinary control to cause tains numerous reforms to the laws of were consensual, unless the parties the sexual act; theft, fraud, bribery, perjury, black- were married to one another. Sexual (3) impose special prohibitions against mail, extortion, obstruction of justice acts compelled by the use of force or sexual activity with inmates or patients; and forgery. Earmarked during the threats would be punishable as sexual (4) eliminate the current spousal ex- criminal law reform hearings as an assault in the first degree, regardless emption for the most serious types of area of District law that has hampered of the age of the victim. sexual assault; and effective law enforcement efforts on Concern over the mistaken public (5) eliminate criminal prohibitions the local level,' this bill is designed to perception of the bill's provisions led against private, noncommercial. con- remedy specific deficiencies in the sensual sexual activity between adults, the Council to delete this provision law rather than to serve as a compre- except for conduct that violates the cur- from the bill and substitute a gender- hensive revision. The bill would elimi- rent incest law. neutral version of the current statu- nate artificial distinctions between the tory rape law. As a result, this act, as Due to misleading coverage by the various forms of theft by consolidat- amended, would impose a penalty of local press that characterized the ing larceny offenses, false pretenses, up to twenty years' imprisonment measure as a bill to legalize teenage embezzlement and receiving stolen upon any person who engages in sex- sex, the debate over this act focused property into a single theft offense. It ual activity with a child under the age on changes to the current statutory also would permit the values of items of sixteen. rape law. The current statutory rape stolen as part of a common scheme or law in the District of Columbia prohib- plan to be aggregated for the purpose its a male of any age from engaging in of being prosecuted as a felony rather sexual activity with a female under Control of Prostitution than as multiple misdemeanors and the age of sixteen. While this law pro- and Sale of Drugs would provide an enhanced penalty for tects females, it does not protect those who steal from a senior citizen. young males, although the Children's The Control of Prostitution and Sale In order to provide more effective Hospital Child Protection Unit re- of Dangerous Drugs in Public Places tools for combating consumer fraud, ports that more than 25 percent of the Criminal Control Act of 1981 was the law of false pretenses would be sexually abused children it handles approved by the Committee on the Ju- changed to cover attempted false pre- are male. diciary at its July 22, 1981 meeting. tenses and promises of future perform- 30 District Lawyer ance made without intent to perform. a fiduciary trust and misuse of public Any alien who was not notified prop- Perjury also would be redefined SO as office. Many of these provisions stem erly. and who could show that his or to include false statements made under from the recommendations of the D.C. her conviction might have these col- penalty of perjury but not under oath. Law Revision Commission. lateral consequences, would be enti- The current obstruction of justice The need to develop a local criminal tled under the bill to withdraw the statute would be expanded to prohibit statute of limitation was supported guilty plea and enter a plea of not obstructions other than those accom- during the criminal law reform hear- guilty. plished by means of an overt threat or ings in particular due to the elimination In an attempt to promote the use of the use of force. of all capital crimes" in the District of restitution, reparations and commu- Another major feature of the bill Columbia. One major amendment sug- nity service, the bill also contains a would be the development of a number gested by the U.S. Attorney for the general provision that statutorily of new statutory offenses, including: District of Columbia that is currently would authorize the court to order (1) a statute prohibiting the taking or being considered would impose no these remedies in addition to any other offering of an unlawful gratuity; time limitation on all prosecutions for condition of the sentence imposed or (2) a statute prohibiting payoffs for past murder, including murder in the sec- as a condition of probation. This provi- official behavior; ond degree. sion was developed in response to (3) a statute prohibiting trafficking in community comments during the crim- stolen property: inal law reform hearings, and would (4) fraud statutes that create two Sentencing serve as a legislative endorsement for degrees of fraud and prohibit schemes to the increased use of these sentencing defraud: Improvements options in appropriate criminal cases. (5) a shoplifting statute; Last, the bill as introduced would (6) a commercial piracy statute that pro- The District of Columbia Sentencing establish standard rules for the making hibits thefts of recordings and other Improvements Act of 1981, also expect- and disclosure of presentence reports. commercial property; ed to be marked up by the Committee However, since the language of the bill (7) a forgery of objects statute; and on the Judiciary this fall, would make merely codifies the current court rules, (8) a credit card fraud statute. certain, discrete changes in local sen- these provisions probably will be tencing procedures. The most impor- deleted at the time of committee mark- The bill also would repeal the cur- tant change suggested by this bill up. rent criminal statutes regarding crimi- would restore split sentencing as a sen- nal libel, mislabeling potatoes and tencing option. Split sentencing is a kosher meats, and procuring the enlist- sentence in which a judge orders the Mandatory Sentencing ment of criminals. defendant to serve a set period of imprisonment followed by a set period Three mandatory sentencing bills of probation. Split sentencing by local now are pending before the Committee Criminal Statute judges was prohibited in 1979 by a on the Judiciary. The first, the Added court decision based on an interpreta- Punishment for Crimes Committed of Limitations tion of the current statutory law. As a With A Dangerous Weapon Act of consequence, judges now are forced to 1981, would impose a five-year man- The District of Columbia Criminal choose between incarceration and pro- datory minimum sentence upon those Statute of Limitations Act of 1981 is bation in sentencing. The language of convicted, for the first time, of com- expected to be marked up by the Com- the bill also would promote sentencing mitting a "crime of violence" while mittee on the Judiciary this fall. The flexibility by permitting a judge to sus- "armed," and would increase to ten bill would, for the first time, create a pend the imposition, as well as the exe- years the current five-year mandatory local statute of limitations for criminal cution, of a sentence. sentence for repeat offenders. This bill offenses. At present, the District of The pending sentencing bill would would not change the current statutory Columbia relies upon the applicable limit ali sentences of probation to five definition of a "crime of violence," federal law. This federal law sets no years or less, and would provide that a which includes not only offenses such time limitation on prosecutions for cap- defendant may not be placed on proba- as murder, rape, kidnapping and rob- ital crimes and a five-year limitation on tion without his or her consent. This bery, but also such crimes as larceny prosecutions for other criminal five-year limit on probation sentences and housebreaking. The bill also would offenses.' would codify local sentencing practice. not amend the current reference to In general, the limitations that would Another provision of the bill would "armed" offenses as offenses commit- be imposed by the bill differ from the require the court to notify aliens of the ted "while armed with or having read- current federal law by providing for no potential, collateral consequences of a ily available any pistol or other firearm time limitation on prosecutions for first guilty plea by giving the following (or imitation thereof) or other danger- degree murder, by setting a ten-year advisement on the record: ous or deadly weapon. Conse- time limitation on prosecutions for sec- quently, the offenses that would be and degree murder, by extending the If you are not a citizen of the United covered by these mandatory minimum time limitation for felony prosecutions States, you are hereby advised that con- viction of the offense for which you have sentences range from murder by use of to six years, by restricting the time been charged may have the conse- a sawed-off shotgun to shoplifting a limitation for misdemeanor prosecu- quences of deportation, exclusion for knife. Under this bill, offenders would tions to three years, and by creating admission to the United States, or denial be denied probation, sentencing under special, extended time limitations for of naturalization pursuant to the laws of the Federal Youth Corrections Act or prosecutions based on fraud, breach of the United States. the possibility of parole prior to the Centember/October 1981 Volume 6 Number 1 31 expiration of their minimum sentence. be pressured to plead to lessor unarmed als for imposing mandatory minimum A similar piece of proposed legisla- counts. Courts would be crowded with sentences on persons who commit a tion also would impose a five-year trials in which there was overwhelming "crime of violence" while armed with. mandatory minimum sentence on first evidence of guilt but the defendant could a pistol or firearm or who manufac- not afford to accept a plea to an armed offenders convicted of committing a ture, distribute, or possess with intent count. Prisons would be crowded with "crime of violence" while "armed," those serving fixed sentences. Parole to manufacture or distribute, certain and a ten-year mandatory minimum authorities would be deprived of discre- controlled substances. The Board of sentence on repeat offenders. How- tion to evaluate the suitability of a pris- Elections and Ethics has approved this ever, the bill, the 1981 Amendment to oner for parole during the mandatory proposed initiative for circulation. If Section 22-3202 of the District of minimum term.' the initiative survives any challenges, Columbia Code, would limit the appli- Supporters of mandatory minimum and if 5 percent of the registered cation of these mandatory minimum sentencing, such as the Metropolitan voters sign petitions demanding that sentences to a "crime of violence" in Police Department, advocated the use the matter be placed on the ballot, then which a firearm, pistol or imitation of sterner sanctions and the need for this initiative measure will be voted on firearm or pistol was used or was read- consistency of sentences for like in the forthcoming election. ily available. The bill also differs in offenses and like offenders. Other sup- that it would not bar application of the porters pointed out the possible deter- Federal Youth Corrections Act to first rent effect of these sentences. offenders. Other Crime A preliminary test of Council senti- The third mandatory minimum sen- ment toward mandatory minimum sen- tencing bill pending before the Commit- Related Legislation tences arose during the floor debate on tee on the Judiciary, entitled the Man- the District of Columbia Uniform Con- The Drug Paraphernalia Act of 1981 datory and Increased Penalty for Offenses trolled Substances Act of 1981. At that would prohibit the use of, or posses- Committed During Release Act of 1981, time, one councilmember presented a sion with intent to use, drug parapher- would impose a five-year mandatory nalia. It also would prohibit the sale or minimum sentence on persons convict- manufacture of such paraphernalia ed of committing a felony offense while under circumstances in which the sell- on pretrial release. The bill also would er knows or has reason to know that impose a one-year mandatory mini- the paraphernalia will be used in viola- mum sentence on persons convicted of tion of the provisions of the bill and im- committing a misdemeanor offense pose a special penalty upon adults who while on pretrial release. Under the bill, deliver drug paraphernalia to certain a prison term must be imposed since minors. judges would be precluded from grant- Unlike the drug paraphernalia provi- ing probation or suspending sentence sion contained in the new drug law, for these mandatory minimum sen- this bill would define the term "drug tences. These mandatory sentences paraphernalia" broadly. During the would have to be served consecutive to course of the criminal law reform hear- any other sentence imposed and would ings, serious concerns were raised apply even if the original charge, for regarding the constitutionality of this which the offender was placed on pre- proposed bill, which follows the model trial release, was dismissed. During the criminal law reform hear- C drafted by the federal Drug Enforce- ment Administration. This model has ings held this year, concerns were been under attack in both state and raised by the U.S. Attorney for the federal courts throughout the country District of Columbia, the D.C. Depart- and judicial decisions have split over ment of Corrections and the D.C. number of amendments, some of the constitutional issues raised. Until Board of Parole, and many community groups that regard the value of manda- which would have imposed mandatory such time as these issues are finally minimum sentences for the manufac- determined by the courts, the commit- tory sentences in general. Written comments by Division V of the D.C. ture, distribution, or possession with tee is expected to delay consideration intent to manufacture or distribute, of this bill. Bar, which opposed enactment, point- certain controlled substances. After The 1981 Amendment to Section ed out the practical difficulties that the Council's general counsel opined 6-1876 of the District of Columbia mandatory minimum sentences can that the amendments were sufficiently Health and Safety Code would make create: broad as to provide a mandatory mini- changes in the penalties imposed for Judges would be deprived of dis- mum sentence for simple transfer by violations of the local gun control law. cretion to tailor sentences to fit the one person to another of a controlled However, this bill is drafted to amend crime and the background of the defend- substance, such as a sleeping pill, the the lesser penalties contained in the ant. Prosecutors would gain some Council defeated the proposed amend- gun control law when it was originally leverage in plea bargaining, but would ment by a vote of ten to three. enacted in 1976, rather than as later be faced with the dilemma of either forc- Recently, a councilmember has filed amended by the Council. ing a defendant to go to trial by refusing to make a plea offer to an unarmed with the Board of Elections and Ethics By a vote of three to one, the Com- count or making a disporportionately a proposed voter initiative. This initia- mittee on the Judiciary voted to disap- lenient offer. Innocent defendants would tive essentially would enact his propos- prove the District of Columbia Bail 32 District Lawyer months, the committee will undertake a final review of the pending proposals, BIL No. Act No. Law Short Title Sponsors based upon comments received during No. and after the criminal law reform hear- ings. In addition, the committee plans - - Inc. Parminentalia An of 1981 Moore 4-3 to review proposed legislation on relat- Added Punishment for Crimes Kant ed criminal law issues, such as a pro- 4-109 - - Committed With A Dangerous posal to provide immunity to insurers Weapon Act of 1981 who report suspected cases of arson to - 1981 Amendment to Section Ray the local authorities and a proposal to 4-119 6-1876 of the District of Shackleton provide compensation to victims of Columbia Health and Safety crime. A more long-range goal of the Code Committee on the Judiciary and its - 1981 Amendment to Section Ray 4-111 - staff is preparing new legislative pro- 22-3202 of the District of posals to continue its work toward Columbia Criminal Code comprehensive review of the local 4-120 - - District of Columbia Sentenc- Clarke criminal law. ing Improvement Act of 1981 Rolark Criminal law reform is not a static Shackleton Clarke process; it responds to new develop- 4-121 - - District of Columbia Statute of ments in local crime problems and it Limitations Act of 1981 Rolark Shackieton depends upon the input of concerned citizens. The D.C. Bar already has con- 4-127 t-iill - District of Columbia Sexual Clarke Assault Reform Act of 1981 Rolark tributed to this process through its Shackleton representation on the D.C. Law Revi- 4-123 4-51 4-29 District of Columbia Uniform Clarke sion Commission, through the written Controlled Substances Act of Rolark comments submitted by Division V 1981 Shackleton and through the insights shared by its Wilson individual members. Now an even greater challenge 4-125 - - Mandatory and Increased Winter Penalty for Offenses Commit- exists for the Bar and its members as ted During Release Act of the city faces the first ballot initiative 1981 in the criminal law area. During the 4-127 District of Columbia Bail Clarke future debate, the Bar is the one ele- - Amendment Act of 1981 ment of our community most able to District of Columbia Theft Clarke 4-133 - help the community-at-large under- - and White-Collar Crimes Act stand the content and the potential of 1981 impact of the proposed initiative. Control of Prostitution and Wilson 4-184 - Sale of Dangerous Drugs in Public Places Criminal Con- trol Act of 1981 Copies of this legisiation may be obtained, free of charge. from the Legislative Ser- 1 D.C. Code $ 49-402(a) (Supp. V 1978). vices Unit of the Council of the District of Columbia by phoning 724-8050, or by , Statement of Executive Branch Agencies writing to Room 28, District Building. Washington. D.C. 20004. on the Bills to Expand and Amend the D.C. Criminal Code Presented to the Committee on the Judiciary, Council of the District of Columbia (March 12, 1981). 3 18 U.S.C. s 3282 (1976). This general Amendment Act of 1981 at its July 22, without bond, of a person charged with statute of limitation applies except as other- 1981 meeting. This attempt to amend first degree murder who poses a risk of wise expressly provided by law. the District's release and pretrial flight or danger to the community. See Whalen V. United States, 445 U.S. detention laws failed, in part, because 684, 686 n. 2 (1980); Furman V. Georgia, 408 of concerns about the effectiveness U.S. 238 (1972); United States V. Lee, 489 A Look Ahead F.2d 1242, 1247 (D.C. Cir. 1973). and potential fiscal impact of the pro- $ Davis V. United States, 397 A.2d 951 posed changes. As presented to the committee, the bill would have: As past experience has demon- (D.C. 1979). strated amply, on both a national and D.C. Code S 22-3202 (1973). Other dan- (1) increased the maximum time of detention, under the preventive deten- state-by-state basis, reform of crimi- gerous or deadly include but are not limited to "a sawed-off shotgun, shotgun, ma- tion laws from sixty to ninety days for nal law is a lengthy process. The pro- chine-gun. rifle; dirk, bowie knife, butcher good cause shown; posals passed by and pending before knife, switchblade knife, razor, blackjack, (2) increased the holding period for the Committee on the Judiciary consist billy, or metallic or other false knuckles." detaining persons arrested while on fed- of partial reforms dealing with distinct , Report of the Criminal Justice Adminis- eral or out-of-state probation or parole and separate areas of criminal law and tration Committee of the Division of the Dis- from five to ten days; and addressing the more pressing local trict of Columbia Bar on the 1981 "Anti- (3) authorized the pretrial detention, crime problems. In the upcoming Crime" Legislation (April 29, 1981) 1. 33 Sentember/October 1981 Volume 6 Number 1 STATE U.S. Department of Justice Office of Legislative Affairs Office of the Washington, D.C. 20530 Deputy Assistant Attorney General MEMORANDUM November 21, 1983 TO: Richard A. Hauser Deputy Counsel to the President The White House FROM: Michael W. Dolan Deputy Assistant Attorney General Office of Legislative Affairs SUBJECT: Legislation Affecting Federal Interest in the District of Columbia. The following new item should be added to my memorandum of November 14th: 7. U.S. Attorney Use of Employment Security Building. The Department continues to oppose H.R. 3707, a bill to transfer the Employment Security Building to the District of Columbia. As the attached correspondence indicates, the building is needed for the relocation of the offices of the United States Attorney for the District of Columbia. cc: Joseph diGenova, U.S. Attorneys Office, D.C. Jay Stephens, Associate Attorney General's Office John Roberts, White House Counsel's office Harold Koh, Office of Legal Counsel Office of Legislative Affairs Office of the Assistant Attorney General Washington, D.C. 20530 Honorable David A. Stockman Director, Office of Management and Budget Washington, D.C. 20503 Dear Mr. Stockman: This is in response to a request from your staff for the views of the Depart- ment of Justice on the Pennsylvania Avenue Development Corporation (PADC) comments on H.R. 3707, a bill "To convey the District of Columbia Employment Security Building to the District of Columbia and to provide for the payment of a note entered into to finance the construction of such building." The Department of Justice opposes this legislation, as I expressed in my letter to Congressman Walter E. Fauntroy, which was transmitted to the Office of Management and Budget for clearance on November 1, 1983. In its views on H.R. 3707, the PADC takes no firm stance either for or against the legis- lation, but suggests an amendment to empower a cost-free transfer of the Employment Security Building and its underlying land, should passage of the bill result in ownership by the District of Columbia. The Department of Justice is opposed to such an amendment, and wishes to reiterate its position that the interests of the Federal Government would be best served if the subject building and land were occupied by the Department of Justice, U.S. Attorney's Office for the District of Columbia. Instead of an amendment to H.R. 3707, the Department of Justice recommends against the enactment of this bill. As stated in my letter to Congressman Fauntroy, the U.S. Attorney's Office occupies space in the U.S. Courthouse and the District of Columbia Court- house. However, the allocation of space in both courthouses is controlled by the Chief Judges of their respective courts. The Attorney General has been notified by the Chief Judges that the U.S. Attorney's Office must relocate from the courthouses to make room for expansion by the courts (Enclosure). It is the wish of the Chief Judges and it is a necessity for continued efficient operation of the U.S. Attorney's Office that the new location for the U.S. Attorney be near both courthouses. The Employment Security Building is the only Federal building which meets the pressing need of the U.S. Attorney's office to relocate. The building is within a short walking distance of both courthouses and contains enough office space to adequately accommodate the U.S. Attorney's Office. The terms of the deed of conveyance make it the prerogative of the Secretary of Labor to designate the occupants of the Employment Security Building. Transfer of title to the District of Columbia would preclude the exercising of this prerogative and would, accordingly, eliminate what appears to be the only acceptable solution to the critical space problem facing the U.S. Attorney's Office. - 2 - For these reasons, the Department of Justice recommends against the enactment of H.R. 3707, and recommends against the submission of such views to Congress which do not likewise recommend against the bill's passage. Thank you for the opportunity to reiterate the Department's concerns on this issue. Sincerely, Robert A. McConnell Assistant Attorney General Office of Legislative Affairs Enclosure UNITED STATES COURT OF APPEALS WASHINGTON, D. C. 20001-2867 not J. SKELLY WRIGHT UNITED STATES CIRCUIT JUDGE October 25, 1983 The Attorney General United States Department of Justice Washington, D.C. 20730 Dear Mr. Attorney General: We are writing to support the request of the United States Attorney for the District of Columbia for office space outside of but within close proximity to the United States Courthouse. Regrettably, because the need by our Courts for space in the Courthouse has increased substantially over the last several years, we must now reclaim major portions of the areas currently occupied by United States Attorney per- sonnel. Having the United States Attorney's Office in the Courthouse has clearly contributed to the efficiency of the judicial system. However, the Courts' space needs must now take priority. We do very much recognize the need for the United States Attorney to be located at least within close prox- imity to the Courthouse. Therefore, we encourage you to pursue actively a space alternative for the United States Attorney which will both enhance the efficiency of that Office and provide ready access to the United States Courts for the District of Columbia Circuit. Sincerely, Skelly Wright Acting Chief Judge U.S. Court of Appeals D.C. Circuit Aubrey E. Robinson Jr. Chief Judge U.S. District Court D.C. Circuit XC: United States Attorney for D.C. U.S. Department OI Justice CIEARANCE -11/1/83 Office of Legislative Affairs IdENticAl LEttER to MARJORIE Holt. Office of the Assistant Attorney General Washington, D.C. 20530 The Honorable Walter E. Fauntroy Chairman, Subcommittee on Fiscal Affairs & Health Committee on the District of Columbia U.S. House of Representatives Washington, D.C. 20515 Dear Mr. Chairman: This letter offers the views of the Department of Justice on H.R. 3707, introduced on July 29, 1983, and currently scheduled for hearings before the Subcommittee on Fiscal Affairs & Health of the Committee on the District of Columbia. For the reasons detailed below, the Department recommends against passage of the proposed legislation. If enacted, H.R. 3707 would transfer to the District of Columbia, without monetary consideration, all right, title and interest of the United States in the District of Columbia Employment Security Building. This building is located at 500 C Street, N.W., less than a block from both the U.S. Court- house and the D.C. Courthouse. By deed of conveyance executed on April 26, 1961, the District of Columbia conveyed to the United States in fee simple the land on which the building is now situated in order to enable the federal government to construct quarters for the U.S. Employment Service and the D.C. Unemployment Compensation Board. These quarters were "to be exclusively occupied by the aforesaid Service and Board for a period of ten years or so long as such use is determined by the Secretary of Labor of the United States or his succes- sor in function to be necessary or advantageous. (Emphasis added.) Construction of the building was financed by the Kansas City Life Insurance Company which holds a 20-year note dated August 21, 1964. The U.S. Department of Labor, which originally made payments on the note directly, currently enables the District of Columbia to meet the obligation by providing an annual Employment Security Administration Grant to the District from which the period- ic payments are deducted. The note should be paid in its entirety by October 1984. This grant is made pursuant to Titles III and IV of the Social Security Act, as amended (42 U.S.C. §§ 501 et seq. and 1101 et seq.) and the Wagner - Peyser Act, as amended (29 U.S.C. § 49 et seq.) The Honorable Walter E. Fauntroy - 2 - The U.S. Attorney's Office for the District of Columbia -- the largest such office in the country, consisting of more than 200 attorneys and a comparable number of support staff -- currently occupies space in the U.S. Courthouse and in the D.C. Courthouse. The allocation of space in both courthouses is controlled by the Chief Judges of their respective courts.2/ Over the past years, the gradual expansion of the federal and D.C. courts has necessitated a conversion of office space to secured chambers and court- rooms which in turn has resulted in a commensurate reduction and/or realloca- tion of space available to the U.S. Attorney's Office. This development has culminated in a determination by the federal judges to convert space in the U.S. Courthouse now occupied by the Criminal and Civil Divisions of the Office by October 1, 1984, as the first step toward reclaiming all U.S. Attorney's Office space in the building; and a determination by the D.C. judges to convert space in the D.C. Courthouse now occupied by the Superior Court Operations of the Office in order to accommodate seven new judges, whose legislative authorization is expected by October 1, 1984. We expect that the entire U.S. Attorney's Office will be evicted from both courthouses within two years. Thus, the space problem confronting the U.S. Attorney's Office here is critical and necessitates expedited consideration. If the U.S. Attorney's Office is to continue to function effectively and efficiently, it must remain proximate to both courthouses. The daily business of the Office involves numerous court appearances as well as the transport of witnesses and of evidence (including weapons, drugs and voluminous records). Requiring Assistant U.S. Attorneys to travel any appreciable dis- tance would compromise the valuable service that they perform to the courts and to the community. Further, in order to optimize efficient management, all divisions of the Office should be centrally located. In our view, the Employment Security Building is the only federal building which meets the pressing need of the U.S. Attorney's Office to relo- cate near the U.S. and D.C. Courthouses. The building is within a short walking distance of both courthouses and contains more than 140,000 square feet of office space which would adequately accommodate all divisions of the Office. It is clear from the terms of the deed of conveyance that as long as the United States holds title to the building, the Secretary of Labor may exercise his prerogative to designate the U.S. Attorney's Office as the future occupant of the building. Transfer of title to the District of Columbia would preclude the exercise of this prerogative and would, accordingly, elimi- nate what would appear to be the only acceptable solution to the critical space problem facing the U.S. Attorney's Office. We therefore recommend against passage of H.R. 3707. 2/ Indeed, the United States Courthouse is the only federal courthouse in the country with respect to which the judiciary is statutorily empowered to allocate space. 40 U.S. C. § 130. 3/ This imperative is consistent with the requirement that the assignment or reassignment of federal space be "the most cost-effective solution practi- cable in each circumstance." 41 C.F.R. § 101-17.102(a); see also, U.S. Court Design Guide (GSA, May 1, 1979) (The United States Attorneys "form an integral part of court activities."). The Honorable Walter E. Fauntroy - 3 - The Office of Management and Budget has advised this Department that there is no objection to the submission of these comments from the stand- point of the Administration's program. Sincerely, ROBERT A. McCONNELL Assistant Attorney General FILE COPY LEGISLATIVE AFFAIRS I 98TH CONGRESS 1ST SESSION H. R. 3707 To convey the District of Columbia Employment Security Building to the District of Columbia and to provide for the payment of a note entered into to finance the construction of such building. IN THE HOUSE OF REPRESENTATIVES JULY 29, 1983 Mr. FAUNTROY introduced the following bill; which was referred to the Committee on the District of Columbia A BILL To convey the District of Columbia Employment Security Build- ing to the District of Columbia and to provide for the payment of a note entered into to finance the construction of such building. 1 Be it enacted by the Senate and House of Representa- 2 tives of the United States of America in Congress assembled, 3 That (a) the Secretary of Labor shall convey to the District of 4 Columbia, without monetary consideration, all right, title, 5 and interest of the United States in and to the parcel of land 6 located in the District of Columbia in lot 826 of square 491 7 described in a deed from the District of Columbia to the 8 United States dated April 20, 1961, and recorded on April 2 1 26, 1961, as instrument number 11232 in liber 11589, 2 folio 135 of the District of Columbia (commonly known as the 3 location of the District of Columbia Employment Security 4 Building). 5 (b) The Secretary of Labor shall convey to the District 6 of Columbia without monetary consideration, all right, title, 7 and interest of the United States in and to any structures, 8 buildings, and improvements on the parcel of land conveyed 9 pursuant to subsection (a). 10 SEC. 2. (a)(1) The liability of the United States for the 11 payment of a note dated August 21, 1964, entered into with 12 the Kansas City Life Insurance Company to finance the con- 13 struction of the District of Columbia Employment Security 14 Building shall not be affected by this Act. 15 (2) The Secretary of Labor shall not make any payment 16 on the note described in paragraph (1) before such payment is 17 required to be made by the terms of the note unless the 18 Mayor of the District of Columbia approves making such pay- 19 ment before such date. 20 (b)(1) The Secretary of Labor shall insure that the pay- 21 ments on the note described in subsection (a)(1) are made on 22 the dates required by the terms of such note and that the 23 District of Columbia reimburses the United States for the 24 amount of each such payment. HR 3707 IH 3 1 (2) To insure that the payments on the note described in 2 subsection (a)(1) are made and that the District of Columbia 3 reimburses the United States for the amount of each such 4 payment, the Secretary of Labor may use funds appropriated 5 under the authorizations contained in sections 501 and 6 901(c)(1) of the Social Security Act (42 U.S.C. 701 and 7 1101(c)(1)) for the District of Columbia to reimburse the 8 United States for any such payment. O HR 3707 IH Los Angeles Times DATE: 11-30-83 PAGE: Part I p.4 A New Assault on the Capital The 600,000 residents of the District of Columbia, district one senator and two representatives. It now who already are denied voting representation in has only one non-voting member of the House. Congress, must now contend with another federal The old argument that the federal government's attempt to deprive them of self-government. The right to ensure public order in the nation's capital new issue is home rule-the right of elected district has precedence over the civil rights of its residents officials to change its criminal laws. is not applicable in this case or in most other cases in Under a proposal by the U.S. Department of which Congress treats the locals as colonials. Justice, the smallest amendment to the district's Were circumstances to require it, the federal criminal code would have to have the approval of government has the instant authority to suspend Congress before it could take effect. the city's charter and to assume full control of Local officials were given no explanation for this municipal affairs. latest attack on self-rule, although the obvious The constitutional amendment that would grant conclusion to be drawn is that the Administration citizens of the district full representation in believes that they are not as competent to govern Congress has little prospect of success. Only 13 of themselves as are the mayors and councils of other the necessary 38 state legislatures have ratified it, major cities. and it is no credit to the California Senate that it Apart from the right to self-determination, it persistently refuses to join the Assembly in strikes us that Congress has more important issues approving the amendment. to debate than the anti-crime laws of a single city. Citizens of Washington must wonder what they In recent years the trend in Congress has been have done to deserve this new assault on their right toward greater self-determination for the capital; to self-determination at the same time that their witness the majority votes in the House and Senate hopes of participating in the national government for a constitutional amendment that would give the are all but vanishing. DOJ-1:183-06 The Washington Times DATE: 11-21-83 PAGE: 11-A The bomb, Justice, and the District Talk about bombs and fallout. D.C's 1974 council and the mayor. But all this misses home-rule charter said either house on the the point. Hill could veto a city-passed law. But last spring the Supreme Court struck down one- The question boils down to whether Con- house legislative vetoes. The fallout from gress should take the time to put aside the court's bomb cast a shadow over Dis- issues like natural gas deregulation, the trict lawmaking. So the Barry administra- defense budget, or federal crime-code tion proposed a solution. Let a city law reform in order to pass judgment on every stand unless the Senate, the House and the change, great and small, in the D.C. president nix it. The House agreed. The criminal code. Yes, if you understand that Senate was about to take it up when Justice the congressional veto approach gives the threw its own bomb. city the initiative and that Congress is Justice wants to make a special case out unlikely to take up its time in gray-area of D.C.'s criminal laws, requiring that any criminal legislation enacted by the city, District change be approved by both houses where liberal politicians have shown an of Congress and the president before occasional inclination to try to dec- becoming law. Justice says the federal gov- riminalize certain "victimless" crimes. ernment has a special responsibility for the Remember, too, that although the Dis- city's diplomats and federal workers. True, trict enacted tougher sentencing laws - although hundreds of thousands of federal mandatory terms for drug and gun-related bureaucrats live and work outside D.C. crimes - than the feds have, credit goes to Ditto for diplomats who live in the suburbs D.C.'s voters, who did it through initiative, or work at the U.N. and in consular offices over the objections of city council members in other cities. All come under local and and the mayor. state criminal laws over which the feds have Justice's bomb may blow away a bit of the no control. city's home-rule powers but will, if enacted Furthermore, Mayor Barry's right in by Congress come January, keep constitu- saying Congress and the president can tional authority over the federal district repeal any District law regarding crime or where, on balance, it's safer - at both ends anything else, and can put a new law on the of Pennsylvania Avenue, instead of the mid- District's books without approval by city dle, in city hall. DOJ-1985-01 39 Memorandum OF United States Attorney District of Columbia Subject: Date: Chadha Dec. 7, 1983 To: From: didis John G. Roberts, Jr. J.E. diGenova Associate Counsel to U.S. Attorney the President The attached is for your information per our conversation. Memorandum OF Subject Date Amendments to the District of Columbia December 1, 1983 Self-Government and Governmental Reorganization Act To From Joseph JidiA E. diGenova Robert A. McConnell Assistant Attorney General United States Attorney Office of Legislative Affairs Thru: John Logan Office of Legislative Affairs On November 22, 1983, this Office was asked to com- ment upon three letters. Those three letters were addressed to Senator Charles McC. Mathias, Chairman of the Subcommittee on Governmental Efficiency and the District of Columbia of the U.S. Senate Committee on Governmental Affairs. The letters were from Marion Barry, Jr., Mayor of the District of Columbia, David A. Clarke, Chairman of the Council of the District of Columbia, and a group of bond counsel to the city. All were dated November 17, 1983. All concur in the legal opinion first voiced by this office that the bond portion of H.R. 3932 could be enacted and thus save the pending bond issues previously authorized by the Council but left in doubt by Chadha. (See Section 1 (i) of H.R. 3932). As you know, during the stages where we became in- volved, our office told the Mayor and others that the bonds could be saved by exactly the language they approve of in the letters we have been asked to comment upon. Earlier in the debate, however, their position was that only H.R. 3932, as written, would suffice to get an unqualified opinion from bond counsel relative to the bond issues. Staff from both the House and Senate Committees were saying publicly through the press that the proposed limited bill to deal only with the bonds was not legally sufficient. Apparently, in the closing hours of the session they thought otherwise. The Mayor's letter, the bond counsel letter and the Chairman of the City Council's letter all agree that the saving legislation (which did not deal with the broad Chadha questions) was sufficient to secure the bond issues. It seems to me that these letters provide the Department with ample justification for its posi- tion relative to the bonds and should be held ready for use during the upcoming debate on amendments to the Home Rule Act. -2- I should add one cautionary note. The debate must be couched in appropriate terms. It is, in my view, a legal as well as a policy debate. The legal question posed is: What is the post-Chadha equivalent of the one house legisla- tive veto. In only one place in the Home Rule Act did Congress retain this vehicle of the one house veto: that was in the area of review of criminal laws enacted by the Council. The equivalent legally of that is a two house re- solution of approval. That is so because the purpose of the one house veto in the original Home Rule Act was to enable Congress, with its busy schedule, to stop something; not to affirmatively act upon something. If Congress and the Department wish to retain that ability to stop something then the two house resolution of approval is the only way. Under the scheme, if either house fails (i.e., one house) to approve an act of the Council in the criminal law area, then the bill fails. Thus, you have a one house veto under constitutionally approved rubrics. There would be no func- tional legal change in the status of this portion of the Home Rule Act. The effect is identical. That assumes, of course, that all wish to retain this degree of control. Such a course seems wise given the degree of Federal interest out- lined in Bob McConnell's letter of November 15, 1983 to Chairman Roth. U.S. Department of Justice Office of Legislative Affairs Office of the Washington, D.C. 20530 Deputy Assistant Attorney General December 9, 1983 MEMORANDUM TO: Mr. Joseph Di Genova United States Attorney for the District of Columbia Mr. John Roberts Office of the Counsel to the President Mr. Koh Shom Office of Legal Counsel FROM: Michael W. Dolan Deputy Assistant Attorney General Office of Legislative Affairs SUBJECT: H.R. 3932 Enclosed for your review is a draft reply to Mayor Barry's letter and Councilmembers Clarke's and Rolark's letter concerning H.R. 3932. Please give either myself or John Logan a call with any comments as soon as possible. Thank you. Enclosure DRAFT Honorable David A. Clarke Chairman Council of the District of Columbia Honorable Wilhelmina J. Rolark Chairperson Committee on the Judiciary Council of the District of Columbia Dear Mr. Clarke and Ms. Rolark: As Fred Fielding indicated in his November 21st letter to you, your correspondence of November 15th has been referred to me for reply. Your letter presented your views on a draft position that the Administration was preparing on H.R. 3932, a bill seeking to correct the constitutional infirmities in the District of Columbia Self Government and Governmental Reorganization Act raised by the Supreme Court's decision in Immigration and Naturalization Service V. Chadha, U.S. , 103 S.Ct. 2764 (1983). Your views on this significant legislation are important to us. Indeed, it is unfortunate that we were never brought into the debate on the bill until the Chairman of the Senate committee with jurisdiction asked the Department for its views. A copy of our formal report to the Senate committee is attached. Our letter presents amendments that would satisfy our concerns. I am hopeful that we can use the Congressional inter-session recess to reach an agreement on the possible amendments to H.R. 3932. Before closing, there is one other point I want to make in reply to your letter. I hope that you understand that our position on H.R. 3932 in no way implies a criticism of the Council of the District of Columbia or its achievements in the criminal justice area. Nor does our position reflect a diminished enthusiasm for the important principle of Home Rule. Rather, our position presents our best efforts to amend the Home Rule Act in the wake of Chadha, a decision that removed from the statute a mechanism that purported - 2 - to control the degree of discretion delegated by Congress. This unconstitutional device is no longer a compromise vehicle. It is the alternatives which our letter attempted to address and what our efforts should be directed toward. Sincerely, Robert A. McConnell Assistant Attorney General U. S. Department of Justice OF Office of Legislative Affairs DRAFT Office of the Assistant Attorney General Washington, D.C. 20530 Honorable Marion Barry, Jr. Mayor District of Columbia Washington, D.C. 20004 Dear Mr. Mayor: As Fred Fielding indicated in his November 17th letter to you, your letter of November 15, 1983 to the President has been referred to me for reply. Your correspondence discusses your position on H.R. 3932, legislation directed to correct the constitutional infirmities in the District of Columbia Self- Government and Governmental Reorganization Act raised by the Supreme Court's decision in Immigration and Naturalization Service V. Chadha, U.S. , 103 S.Ct. 2764 (1983). The Administration appreciates your perspective on this matter and the courtesy your office has extended in advising us of your views. I hope you understand that the Department's posi- tion on this legislation was discussed in response to a request for our views from the Chairman of the Senate Committee with jurisdiction over the legislation. As part of the process where- by the Department comments on numerous bills pending before the Congress, our position was determined and reviewed as quickly as possible. It is surprising that neither the House Committee nor the District of Columbia sought the Department's views on this matter, especially since we have always expressed a substan- tial interest in legislation affecting criminal justice in the District of Columbia. The issue at stake, the repeal of the legislative veto pro- visions in current law and determining the proper alternative, is, in a sense, one of first impression. Until the Court's de- cision in Chadha, the legislative veto was a much used compromise device. It purported to permit Congress to hold in check discre- tion which had been delegated by law. The Supreme Court's deci- sion, of course, precludes further utilization of this mechanism. Whether delegated authority should be subject to reversal only by enactment of a joint resolution, or whether the exercise of discretion should be implemented only by the enactment of a joint resolution, or whether some other discretion limiting device should be used, must now be resolved in a large number of statutes. Because there is no ready replacement for the legislative veto device, each statute must be carefully examined to determine the appropriate balance of competing interests involved. Our report to the Senate Committee, a copy of which is enclosed, expresses our position on this issue as it relates to Titles 22, 23 and 24 of the District of Columbia Code. I hope that we can use the inter-session recess period to agree on amendments that we can all support. Sincerely, ROBERT A. McCONNELL Assistant Attorney General - 2 - OF U.S. Department of Justice Office of Legislative Affairs Office of the Assistant Attorney General Washington, D.C. 20530 15 NOV 1983 Honorable William V. Roth, Jr. Chairman Committee on Governmental Affairs United States Senate Washington, D.C. 20510 Dear Mr. Chairman: Pursuant to your request, this letter presents the views of the Department of Justice on H.R. 3932, a bill "to amend the District of Columbia Self-Government and Governmental Reorganiza- tion Act, and for other purposes," as passed by the House of Representatives on October 4, 1983. We oppose the enactment of this legislation unless it is amended consistent with the discus- sion set forth below. H.R. 3932 would amend the District of Columbia Self-Govern- ment and Governmental Reorganization Act, Pub. L. 93-198, 87 Stat. 774 (1973), as amended, ("Act"). The legislation is in response to the Supreme Court's decision in Immigration and Naturalization Service V. Chadha, 103 S.Ct. 2764 (1983) which struck down as unconstitutional so-called "legislative veto" devices. 1/ The Act contains several such devices 2/ purporting to authorize Con- 1/ The Supreme Court has also affirmed the invalidity of two other legislative veto provisions. See Process Gas Consumers Group V. Consumers Energy Council or America, 103 S. Ct. 3556 (1983), affirming Consumers Energy Council of America V. FERC, 673 F.2d 425 (D.C. Cir. 1982), and Consumers Union, Inc. V. FTC, 691 F.2d 575 (D.C. Cir. 1982). 2/ The Act contains four provisions which may be characterized as legislative vetoes. These are: (1) Section 303 (b) provides that "an amendment to the charter shall take effect only if both Houses of Congress adopt a concurrent resolution approving such amendment." (2) Section 602 (c) (1) provides that with respect to acts ef- fective immediately due to emergency circumstances and acts pro- posing amendments to Title IV of this Act "no such act shall take effect until the end of the 30-day period and then only if during such 30-day period both Houses of Congress do not adopt a concurrent resolution disapproving such act." gress to disapprove actions of the District of Columbia Government without complying with the constitutional requirements of legis- lation. The Administration generally supports the approach of H.R. 3932, which would correct the constitutionally invalid portions of the Act by requiring Congressional action disapproving acts passed by the D.C. City Council to take the form of legislation passed by both Houses and presented to the President for approval or disapproval. In one narrow area, however, the Administration believes that it would be more consistent with Congress' prior treatment under the Act to require affirmative approval of acts passed by the D.C. City Council rather than opportunity for disapproval. We recommend that H.R. 3932 be amended to provide that City Council laws amending Titles 22, 23 and 24 of the District of Columbia Code -- which relate to criminal law, criminal procedure and prisoners-- only take effect upon passage by Congress of a joint resolution of approval. This approach will cure the constitutional infirmities pointed out by the Chadha decision, while retaining the special treatment accorded Titles 22, 23, and 24 under the existing Act. Under the Constitution, Congress has the exclusive power to legislate for the District of Columbia. Art. I, $8, cl. 17. Pur- suant to this authority Congress has enacted Titles 22, 23 and 24 of the D.C. Code. The Department of Justice, through the United States Attorney for the District of Columbia, has been vested with the prosecutive authority in the United States District Court and the District of Columbia Superior Court. D.C. Code 523-101. Indictments are sought, and prosecutions pursued in the name of the United States of America. Similarly, this Department, through the U.S. Marshal for the District of Columbia conducts the service of criminal process, provides courtroom security, transports prisoners, and returns to the District of Columbia defendants arrested in other jurisdictions and wanted for prose- cution in the District of Columbia. The U.S. Marshals Service utilizes its authority under law to serve Superior Court felony subpoenas anywhere in the United States. D.C. Code 11-942(b). Footnote 2 continued from page 1 (3) Section 602 (c) (2) provides that any Act affecting Title 22, 23, or 24 of the District of Columbia Code "shall take effect only if one House of Congress does not adopt a resolution disapproving such act." (4) Section 740(a) provides that either the House or the Senate may adopt a resolution terminating emergency presidential authority over the Metropolitan Police Department. - 2 Finally, all persons convicted in the District of Columbia are committed to the custody of the Attorney General, who, through the Department's Bureau of Prisons, designates the place of confinement. D.C. Code $24-425. 3/ The Superior Court of the District of Columbia, where juris- diction for local offenses rests, is a federal court created pur- suant to Article I of the Constitution. Palmore V. United States, 411 U.S. 389, 397 (1973). The judges of the Superior Court and the Court of Appeals are appointed by the President. D.C. Code $ § 11- 101, 11-102, 11-301, and 11-1501(a). A single jury system for grand and petit juries serves both the Superior Court and Federal District Court. A grand jury of one court may return indictments to the other. D.C. Code $ 511 - 1902, 11-1903(a). The federal government is, accordingly, deeply interested in the prosecution of crimes under the D.C. Code, their determination before the courts, and the handling of prisoners convicted under the Code. The federal government owns approximately 41% of all land in the District. Over 200 buildings are owned or leased by the federal government. Over 445,000 federal employees work in the Washington Metropolitan area. As a result, the District draws both the nation's citizens and those of other countries for pur- poses ranging from conducting business with the federal govern- ment to touring the capital. Moreover, the existence of a sizable diplomatic community underscores the federal interest in the enactment, enforcement and interpretation of the criminal laws governing the District. 3/ By agreement with the Government of the District of Columbia most District of Columbia prisoners are sent to the Lorton Reformatory. 4/ Our concerns in these areas do not take place in a vacuum. Presently before the D.C. Council are three bills, Bill 5-16, the Parole Act of 1983, Bill 5-244, the Prison Overcrowding Emergency Powers Act of 1983, and Bill 5-245, the District of Columbia Sen- tencing Improvements Act of 1983, which raise substantial concern. Bill 5-16 would reduce the minimum period of detention to 10 years and would be applicable to individuals incarcerated for such crimes as rape, murder and armed offenses. Bill 5-244 would permit, as a means of budget control, the release into the community of con- victed individuals. Bill 5-245 would expand the time for granting a motion to reduce a sentence from 120 days to one year. While this Department has strongly opposed these proposals (and of course, the Council has yet to act upon them), we believe more importantly, that Congress, through the legislative process, should retain the opportunity to review the wisdom of such proposals. - 3 - Special treatment for Titles 22, 23 and 24 is consistent with the existing Act and its legislative history. Specifically, in only one area did Congress reserve to itself to veto by vote of only one House the acts of the City Council - Titles 22, 23 and 24 of the D.C. Code. Act $602(c)(2). See also H.R. Rep. No. 482, 93d Cong., 1st Sess. (1973). In fact the original bill, as passed by the House of Representatives, prohibited the soon to be established Council from legislating in the criminal law area. H.R. 9682, 93d Cong., 1st Sess., $602 (a) (8) (1973). The Senate version contained no such prohibition. S. 1435, 93d Cong., 1st Sess. (1973). The conference version represented a compromise by inserting a one house veto. Pub. L. No. 93-198, $602 (c) (2), 87 Stat. 774 (1973) 5/ The Supreme Court's decision in Immigration and Naturaliza- tion Service V. Chadha, 103 S. Ct. 2764 (1983), now requires this arrangement to be reworked. 6/ Our objection to H.R. 3932 is that the federal government is now asked to surrender permanently its authority in an area of its plenary responsibility. We believe that in light of the historic responsibility of the federal government for criminal law enforcement in the district, the interests of both the citizens of the District of Columbia and the Nation as a whole are better served by continuing the special treatment accorded Titles 22, 23 and 24 and maintaining the pri- mary responsibility of the Congress and the President in this area. This responsibility can be preserved by requiring a joint resolution of approval for D.C. Council amendments to Titles 22, 23 and 24 of the District of Columbia Code. In this (Footnote Continued from Page 3) 4/ Additionally, in 1981, the D.C. Council passed a Sexual Assault Reform Act. Among its provisions was one which lowered the age of consent for minors in statutory rape cases. Another provision would have reduced the maximum sentence for both forcible and statutory rape from life to 20 years imprisonment. The penalty for incest was reduced. The proposal also reduced the penalty for forcible rape to a 10 year maximum if the victim was physically or mentally incapable of consenting or resisting. The House of Representatives passed a resolution disapproving the proposal. H. Res. 208, 97th Cong., 1st Sess., 127 Cong. Rec. H6762 (1981). 5/ We also note that during the first two years subsequent to the date which elected members of the initial Council took office, the Council was prohibited from legislating in this area while a study of the District of Columbia Criminal Code was undertaken for the Congress. This was later extended to four years. See $602 (a) (9) of the Act. 6/ See Statement of Edward C. Schmults, Deputy Attorney General, before the Subcommittee on Administrative Law and Governmental Relations, Committee on the Judiciary, House of Representatives (July 18, 1983). - 4 - connection, it should be noted that this proposal will give the District government more authority than it has under present law in every area except the criminal field. It is important to be aware that the question at stake trans- cends the issues of the moment and that there is no inherent con- flict between the District and federal government. The issues in H.R. 3932 result from the unique federal and district relation- ship embodied in present law. This Department values its repre- sentation of the citizens of the District of Columbia and shares their goal of ensuring that a fair, efficient, and effective criminal justice system be in place. In conclusion, we oppose enactment of H.R. 3932 unless it is amended consistent with the views expressed in this letter. The Office of Management and Budget has advised this Depart- ment that there is no objection to the submission of this report from the standpoint of the Administration's program. Sincerely, ROBERT A. McCONNELL Assistant Attorney General 7/ We are sensitive to the need of the District of Columbia to have the ability to raise revenues through the municipal bond mar- ket. Section (1) (i) of H.R. 3932 is directed toward ratifying previous actions of the D.C. Council with respect to these bonds. We would suggest, however, that $ (1) (i) be clarified so as not to imply that actions of the D.C. Council which never became effective, whether because they were subject to Congressional action or otherwise, are ratified. - 5 -