From: "Saved by Windows Internet Explorer 7" Subject: Michael New Case Date: Tue, 22 May 2007 10:38:29 -0400 MIME-Version: 1.0 Content-Type: multipart/related; type="text/html"; boundary="----=_NextPart_000_0000_01C79C5D.5615CF70" X-MimeOLE: Produced By Microsoft MimeOLE V6.0.6000.16386 This is a multi-part message in MIME format. ------=_NextPart_000_0000_01C79C5D.5615CF70 Content-Type: text/html; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable Content-Location: http://www.wjopc.com/site/constitutional/cert_brief10.html Michael New Case
No. 97-1375=20

In The=20
Supreme Court of the United States=20
October Term, 1997=20
________________

Michael G. New,=20
Petitioner,=20

v.

William S. Cohen,=20
Secretary of Defense, et al.,
Respondents.=20
________________

On Petition for Writ of Certiorari=20
to the United States Court of Appeals=20
for the District of Columbia Circuit=20
________________

Brief of=20
National Citizens Legal Network=20
as Amicus Curiae in Support of Petitioner=20
________________

Michael Boos=20
National Citizens=20
Legal Network=20
11094-D Lee Highway #200=20
Fairfax, VA 22030=20
(703) 352-4788

Attorneys for=20
National Citizens=20
Legal Network

William J. Olson*=20
John S. Miles=20
Alan Woll=20
John F. Callender, Jr.=20
William J. Olson, P.C.=20
Suite 1070=20
8180 Greensboro Drive=20
McLean, VA 22102=20
(703) 356-5070

*Counsel of Record=20
March 23, 1998 =






TABLE OF=20 CONTENTS


Table of Authorities

Interest of the = Amicus=20 Curiae

Statement of the Facts
Summary of Argument

Argument
Conclusion

TABLE OF AUTHORITIES

STATUTES
28 U.S.C. =A7 171(a)
28 U.S.C. =A7 2241

CASES
Baker v. Carr, 369 U.S. 186 (1962)=20
Clinton v. Jones, 520 U.S. ___, 117 S.Ct. 1636 = (1997)=20
Commodity Futures Trading Commission v. Shor 478 = U.S.=20 833 (1986)=20
Fay v. Noia, 372 U.S. 391 (1963)=20
Marbury v. Madison, 5 U.S. (1 Cranch) 137 (1803) =
McElroy v. Guarliardo, 361 U.S. 281 (1960)=20
New v. Cohen, 129 F.3d 639 (D.C. Cir. 1997)=20
New v. Perry, 919 F. Supp. 491 (D.D.C 1996)=20
Northern Pipeline Co. v. Marathon = Pipe Line=20 Co., 458 US 50 (1982)=20
Noyd v. Bond, 395 U.S. 683 (1969)=20
Powell v. McCormack, 395 U.S. 486 (1969)=20
Reid v. Covert, 354 U.S. 1 (1957) = Scheslinger v.=20 Councilman,
420 U.S. 738 (1974)=20
Toth v. Quarles, 350 U.S. 11 (1955)=20
U.S. v. Will, 449 U.S. 200=20
Youngstown Sheet & Tube Co. v. Sawyer, 343 = U.S. 579=20 (1952)

MISCELLANEOUS
Sup. Ct. R. 37.3(a)=20
Sup. Ct. R. 37.6

No. 97-1375


In The=20
Supreme Court of the United States=20
October Term, 1997=20
________________

Michael G. New,=20
Petitioner,=20

v.

William S. Cohen,=20
Secretary of Defense, et al.,
Respondents.=20
________________

On Petition for Writ of Certiorari=20
to the United States Court of Appeals=20
for the District of Columbia Circuit=20
________________

Brief of=20
National Citizens Legal Network=20
as Amicus Curiae in Support of Petitioner=20
______________________

Interest of the=20 Amicus Curiae

Amicus Curiae National Citizens Legal Network (NCLN) is a = project of=20 Citizens United Foundation,= (1)=20 and it is the instrument through which Citizens United Foundation = advances its=20 views in the courts. Citizens United Foundation is a nonprofit, = nonpartisan,=20 educational organization established to conduct research and to inform = and=20 educate the public on a variety of issues of national importance, = including

issues related to sovereignty, separation of powers, the original = intent of=20 the Framers and the correct interpretation of the United States = Constitution.

NCLN and Citizens United Foundation believe that the pending case = presents=20 the Court with important constitutional questions touching American = sovereignty=20 and separation of powers involving the original intent of the Framers = and the=20 correct interpretation of the Constitution. In particular, this brief = urges the=20 Court to grant Mr. New's petition for a writ of certiorari in order to = determine=20 whether the court of appeals has decided correctly that Mr. New has no = right to=20 have his habeas corpus petition heard until he exhausts his appeals = before a=20 military court that has no authority to rule on his constitutional = claims.

Statement of Facts

On August 21, 1995, United States Army Medical Specialist Michael G. = New=20 learned that he and the other members of his unit would soon be deployed = to=20 Macedonia to serve as "United Nations Fighting Persons." As such, Mr. = New would=20 be required to wear a United Nations uniform, carry United Nations=20 identification, and forfeit the protections afforded United States = servicemen by=20 the Geneva Convention, in favor of the protections afforded "United = Nations=20 Fighting Persons" by the UN Charter. He would also fight under the = command of=20 officers, each of whom swore not to seek or accept instructions with = respect to=20 the performance of any duties from any government or authority other = than the=20 United Nations (including anyone in the command structure of the U.S. = Army up to=20 and including the President of the United States).

Mr. New protested, requesting transfer to a unit not under United = Nations=20 command, or alternatively, an honorable discharge from the Army. On = October 10,=20 1995, Mr. New was ordered to don the United Nations uniform, and he = refused to=20 do so, explaining his belief that the order was illegal and = unconstitutional. He=20 was convicted by court martial on January 24, 1996 for failure to obey a = lawful=20 order, and sentenced to a Bad Conduct Discharge.

Mr. New petitioned for a writ of habeas corpus, contending, inter = alia, that it was unlawful for him to wear the badges or accept the = office=20 of a foreign government, and seeking an honorable discharge. His = petition was=20 denied by the district court, New v. Perry, 919 F. = Supp. 491=20 (D.D.C. 1996), and the district court's judgment was affirmed by the = court of=20 appeals, New v. Cohen, 129 F.3d 639 (D.C. Cir. = 1997).

Mr. New's sentence was suspended pending appeal, and Mr. New is = currently on=20 involuntary leave from the Army.

Summary of Argument

The Petition for Writ of Certiorari presents an important question = involving=20 the authority and obligation of Article III courts to adjudicate claims = based on=20 the Constitution. The court of appeals denied the claim for habeas = corpus relief=20 of the petitioner, Michael New, on the theory that comity requires = Article III=20 courts to await the adjudication of collateral issues by the Article I = military=20 tribunals. But the law does not require such abstention where the = underlying=20 constitutional claim properly is one for determination by the Article = III court,=20 and not an Article I tribunal, and where the petitioner's claim cannot = be=20 resolved by the Article I tribunal.

In this case, Michael New's constitutionally-based claim that he is = entitled=20 to an honorable discharge from the United States Army will not be = adjudicated by=20 the military courts' review of the bad conduct discharge thus far = decided=20 against him. Such determinations fall within the province of Article III = courts.=20 Moreover, the prior decisions of this Court indicate that habeas corpus=20 jurisdiction for Article III adjudication of Mr. New's claim presently = lies.=20 Finally, if there is no such Article III adjudication at this time, and = the=20 court martial verdict against Mr. New is sustained by the military = tribunals,=20 the court of appeals offers no assurance that habeas or other relief in = an=20 Article III court would be available.

By refusing to provide Article III review of the merits of Mr. New's = claim at=20 this time, while requiring Mr. New to await final disposition of the = collateral=20 charges against him in the military courts, the court of appeals' = decision=20 doubly prejudices Mr. New's constitutional rights. Applying the = principle of=20 comity so as to preclude adjudication of Mr. New's constitutional claim = by an=20 Article III court neither accords with the Constitution nor follows the = prior=20 decisions of this Court. Therefore, this amicus curiae = believes, with=20 the petitioner, that the court of appeals' decision should be reversed. = This=20 issue is a proper one for full briefing and review by this Court. = Certiorari=20 should be granted.

Argument

The Petition for Certiorari being supported by this amicus = curiae=20 presents to the Court for determination the fundamental issue of whether = the=20 principle of comity as applied to appeals pending before military = tribunals=20 requires Article III civil courts to deny habeas corpus relief to a = petitioner=20 whose important constitutional claims could otherwise escape = adjudication by an=20 Article III court.

The decision of the lower courts would require the petitioner, = Michael New,=20 to exhaust military appeals of his court martial conviction, in a case = where=20 that conviction was based exclusively on Mr. New's principled refusal to = violate=20 his oath as a member of the Armed Forces by refusing to obey an illegal = and=20 unconstitutional order to transfer his allegiance to a foreign sovereign = by=20 becoming a soldier of the United Nations. The lower courts refused to = entertain=20 habeas relief, while military appeals are pending, which may be Mr. = New's only=20 opportunity for review by an Article III court.

The Court must determine whether military tribunals are the = appropriate forum=20 to rule on the validity of the order given to Mr. New, determining the = merits of=20 Mr. New's constitutional and other claims= (2)

which the district court found had raised "important = issues,=20 implicating the balance of power between the President = as=20 Commander-in-Chief and the Congress and the relationship between the = United=20 States and the United Nations" and which the district court "has=20 taken...seriously." New v. Perry, 919 = F.=20 Supp. 491, 497-500 (D.D.C. 1996) (emphasis added).

The Supreme Court has determined that the principle of "comity" = dictates that=20 "when a serviceman charged with crimes by military authorities can show = no harm=20 other than that attendant to resolution of his case in the military = court=20 system, the federal district courts must refrain from intervention...."=20 Schlesinger v. Councilman, 420 U.S. 738, 758 (1974). = As=20 explained by the district court, "[d]eference by the federal court = avoids=20 friction between the two court systems and may avert unnecessary or = duplicative=20 proceedings in the event that the military outcome obviates the need for = judicial intervention." New v. Perry, 919 F. Supp. = 491,=20 496.

In the instant case, however, requiring Mr. New to continue = adjudicating his=20 case before military tribunals is, at best, an exercise in futility. = Rather than=20 avoiding duplicative proceedings, deference to the military tribunals=20 virtually guarantees duplicative proceedings, assuming = that Mr.=20 New's claim eventually would be entertained by an Article III court, a = matter=20 that is far from certain, as discussed infra.

The court of appeals stated that Mr. New's conviction was reviewable = by the=20 Army Court of Criminal Appeals, with the possibility of a discretionary = appeal=20 to the Court of Appeals for the Armed Forces which is composed of = civilian=20 judges, and is a legislative Article I court. New v. Cohen, 129 = F.3d=20 639, 642 (D.C. Cir. 1997).

A military tribunal comprised of military personnel subordinate to = the=20 President of the United States is clearly not the proper forum to = consider=20 "unprecedented" and "important issues, implicating the balance of power = between=20 the President as Commander-in-Chief and the Congress and the = relationship=20 between the United States and the United Nations" as stated by the = district=20 court. The Court of Appeals for the Armed Forces, likewise, as a = legislative,=20 Article I Court, has no meaningful role in determining the proper = constitutional=20 relationship between the Congress and the President. In neither case is = there a=20 need to tap the special expertise of the military courts, as the = constitutional=20 issue raised is clearly beyond both their expertise and competence.

Since the very early days of the Republic, it has been firmly = established=20 that Article III courts are vested with the power and obligation to = interpret=20 the Constitution and laws of the United States arising thereunder. "The=20 constitution vests the whole judicial power of the United states in one = Supreme=20 Court, and such inferior courts as congress shall, from time to time, = ordain and=20 establish. This power is expressly extended to all cases arising under = the laws=20 of the United States." Marbury v. Madison, 5 U.S. (1 = Cranch)=20 137, 173-74 (1803). "It is emphatically the=20 province and duty of the judicial = department=20 to say what the law is." Id. at 177 (emphasis added).

When presented with an actual case or controversy, the judicial = branch has=20 the obligation to define limits of the powers of the various branches of = the=20 federal government, the essence of Mr. New's constitutional claims. In=20 Marbury v. Madison, for example, the Court concluded = that it=20 did not have the power to issue a writ of mandamus to the Secretary of = State,=20 because the issuance of such a writ required the exercise of original=20 jurisdiction and the Constitution limited the Court's original = jurisdiction to=20 all "cases involving ambassadors, other public ministers and consuls, = and those=20 in which a state shall be a party." Id. at 174.

In Powell v. McCormack, 395 U.S. 486 (1969), the = Court=20 construed Congress's powers. It held that the House of Representatives = was=20 limited to applying only the standing qualifications expressly = prescribed by=20 Article I, Section 5 of the Constitution in judging the qualifications = of its=20 members

The Court has also had occasion to define the contours of = Presidential powers=20 and privilege. For example, in Youngstown Sheet & Tube Co. = v.=20 Sawyer, 343 U.S. 579 (1952), the Court held that the President, = absent=20 statutory authorization, did not have the power to order the seizure and = operation of the nation's steel mills by the government. More recently, = in=20 Clinton v. Jones, 520 U.S. ___, 117 S.C. 1636 (1997), = the=20 Court held that the Constitution does not accord the President temporary = immunity from civil litigation arising out of events occurring before he = took=20 office.

Unquestionably, the judicial branch has been viewed by this Court as = being=20 vested by the Constitution with the power and obligation to define the = powers=20 and privileges of a particular branch of government. As the Court = explained in=20 Baker v. Carr, 369 U.S. 186 (1962):

Deciding whether a matter has in any measure been committed by the=20 Constitution to another branch of government, or whether the action of = that=20 branch exceeds whatever authority has been committed, is itself a = delicate=20 exercise in constitutional interpretation, and is a responsibility of = this Court=20 as ultimate interpreter of the Constitution. [Id., at 211.]

Such power should not be delegated to, shared with, or exercised by = military=20 tribunals or Article I courts. In Northern Pipeline Co. = v. Marathon Pipe Line Co., 458 U.S. = 50=20 (1982), the Court held that 28 U.S.C. =A7 1471, by which Congress made a = broad=20 grant of jurisdiction to Article I bankruptcy courts, is = unconstitutional. As=20 the plurality opinion states: "The judicial power of the United States = must be=20 exercised by courts having the attributes prescribed in Art. III." = Id.,=20 p. 59. The Court, in Commodity Futures Trading Commission = v.=20 Shor, explained the fundamental rationale underlying this rule, = stating=20 that Article III, section 1 serves "to safeguard litigants' 'right to = have=20 claims decided before judges who are free from potential domination by = other=20 branches of government.'" 478 U.S. 833, 848 (1986) (quoting U.S. = v.=20 Will, 449 U.S. 200, 218 (1980)).

The right of litigants discussed in Shor has been protected = by this=20 Court despite government appeals for deference to the military courts. = Thus,=20 where an Article I military tribunal has assumed jurisdiction over an=20 individual, the Court has recognized that he or she may petition an = Article III=20 court for habeas corpus relief when the petition raises a substantial = and=20 unresolved constitutional claim. In Reid v. Covert, = 354 U.S. 1=20 (1957), the Court affirmed the power to the district courts to grant = relief to=20 the spouses of military personnel who were unconstitutionally subjected = to=20 prosecution under the Uniform Code of Military Justice. Similarly, in=20 McElroy v. Guarliardo, 361 U.S. 281 (1960), the Court = held=20 that a civilian employee of the armed forces serving with the armed = forces in a=20 foreign country cannot constitutionally be subjected to a court-martial = in time=20 of peace. And in Toth v. Quarles, 350 U.S. 11 (1955), = the=20 Court held that a former Air Force serviceman could not constitutionally = be=20 subjected to trial by court-martial for crimes alleged to have been = committed=20 while he was in the military. In each of these cases, the Court = determined that=20 adjudication of the petitioner's claim should proceed immediately in the = Article=20 III court, and should not await further proceedings by the Article I=20 tribunal.

Although not explicitly stated within these opinions, in each case = the=20 implicit justification for deciding the merits of the petitioners' = claims was=20 that Article III courts were the appropriate forum for adjudicating what = were=20 found to be substantial constitutional claims. Indeed, the Court took = note of=20 this very point in Noyd v. Bond, 395 U.S. 683 (1969),=20 commenting that in Reid, McElroy and Toth,=20 supra, it "vindicated complainants' claims without requiring = exhaustion=20 of military remedies," because "we did not believe that the expertise of = military courts extended to the consideration of constitutional claims = of the=20 type presented." Id. at 696, n.8.

With respect to the issue of expertise, the court of appeals found = that the=20 case of Schlesinger v. Councilman, 420 U.S. 738 = (1975), was=20 controlling, and under that case that "military courts are capable of, = and=20 indeed may have superior expertise in, considering challenges to their=20 jurisdiction over disciplinary proceedings." New v. = Cohen, 123=20 F.3d 639, 645. But in Councilman the issue presented was = whether a=20 service member's alleged offense is "service related." That authority is = inapposite here, where important constitutional issues have been raised, = as=20 discussed, supra.

The decision of the court of appeals violates Mr. New's right to have = his=20 constitutional claims heard before an Article III court as the proper = forum for=20 adjudicating substantial constitutional claims. Instead, the court of = appeals=20 held that Mr. New present those claims "to the military authorities = reviewing=20 his case." New v. Cohen, 129 F.3d 639, 646.

The Article III Courts' refusal to accept jurisdiction of this = substantial=20 constitutional claim should not stand, even if Mr. New would ultimately = be able=20 to pursue his claims in an Article III Court. There is no reason to = require Mr.=20 New to suffer needless delay, force him and his attorneys to waste = precious=20 resources, and put his life on hold for an even longer period, while the = military courts conduct a judicial exercise for which they were never = designed.=20 The factual record in this case is fully developed, and an Article I = court is=20 not competent to rule on Mr. New's constitutional claims in any event. = As a=20 consequence, requiring Mr. New to exhaust his military appeals prior to = seeking=20 habeas relief would be pointless and wasteful. As the Court explained in = Fay v. Noia, 372 U.S. 391, 437 (1963),"comity = does=20 not demand that such a price in squandered judicial resources be paid; = the needs=20 of comity are adequately served in other ways."

But there is an even greater risk. Unless the district court is = directed to=20 proceed with the habeas corpus petition, there is no guarantee that Mr. = New=20 would eventually be able to have his claims aired in an Article III = court. Both=20 the district court and the court of appeals appeared to indicate that = Mr. New=20 might, but not necessarily would, have his claims heard on the merits in = an=20 Article III court.

The district court stated: "[o]nce the military proceedings are = completed,=20 Specialist New may either move to reopen this proceeding or file a new = petition=20 for a writ of habeas corpus." The district court did not, and perhaps = could not,=20 say whether the district court would consider the petition on its = merits.

The court of appeals was much more guarded in its assessment of the=20 likelihood of Mr. New obtaining review in an Article III court, and = implicitly=20 questioned whether the district court was correct in stating that habeas = corpus=20 would be an available remedy. The court of appeals seemed to assert that = only if=20 the court-martial jury had ordered his incarceration in a military = prison, a=20 scenario which the Court said is "now foreclosed," could he have filed a = habeas=20 petition in federal district court. New v. Cohen, 129 F.3d at = 647.= (3)

That option having been foreclosed, a conviction with an other than = honorable=20 discharge would leave him only two possible options, according to the = court of=20 appeals. First, "[i]f he suffers monetary losses as a result of his = discharge,=20 he may be able to collaterally attack the underlying = conviction=20 in the United States Court of Federal Claims, an Article I court under = 28 U.S.C.=20 =A7=A7 171(a). Second, "New also might be able to bring = an action=20 in district court seeking nullification of the conviction underlying his = bad=20 conduct discharge. And by way of further caveat, the court of appeals = stated=20 that "[i]n delineating these scenarios, however, we do not mean = to=20 suggest that New's claims have merit or that a federal = court=20 would even reach the merits of his arguments." New v. = Cohen,=20 129 F.3d at 648 (emphasis added).

In truth, by requiring Mr. New to exhaust his military remedies = before an=20 Article III court will entertain a habeas corpus petition, the court of = appeals=20 may have effectively denied Mr. New the right to have his important=20 constitutional claims ruled on by an Article III court within the = judicial=20 branch of the federal government. Surely, the principle of comity, = however=20 important, cannot be allowed to result in the complete abrogation of Mr. = New's=20 right to a hearing on the merits of his constitutional claims before an = Article=20 III court. To provide Mr. New his proper day in court, the district = court should=20 be directed by the court of appeals to entertain Mr. New's habeas = petition=20 without further delay.

Conclusion

For the reasons stated above, the National Citizens Legal Network = urges the=20 Court to grant the Petition for Writ of Certiorari of Michael New.


Respectfully Submitted,

William J. Olson*=20
John S. Miles=20
Alan Woll=20
John F. Callender, Jr.=20
William J. Olson, P.C.=20
Suite 1070=20
8180 Greensboro Drive=20
McLean, VA 22102=20
(703) 356-5070

Michael Boos=20
National Citizens=20
Legal Network=20
11094-D Lee Highway #200=20
Fairfax, VA 22030=20
(703) 352-4788

Attorneys for=20
National Citizens Legal Network
*Counsel of Record=20
March 23, 1998=20






1. This brief was not authored in whole or in part = by=20 counsel for any party. It has been funded in its entirety by the = amicus=20 curiae. See Sup. Ct. Rule No. 37.6.

The amicus curiae requested and received the written = consents of the=20 parties to the filing of this brief. Such written consents, in the form = of=20 letters from counsel of record for the parties, have been submitted for = filing=20 to the Clerk of Court. See Sup. Ct. Rule No. 37.3(a).

2. Mr. New has challenged the President's legal = authority,=20 as Commander-in-Chief of the Armed Forces of the United States, to order = Mr. New=20 to become a soldier in the armed forces of the United Nations in = violation of=20 his oath of enlistment in the U.S. Army to support and defend the = Constitution=20 of the United States of America, as well as the terms of that = enlistment.

3. The court of appeals' view of the = unavailability of=20 post-discharge habeas relief could be accurate. Federal habeas corpus = relief is=20 available to persons held "in custody" in violation of the Constitution = of the=20 United States or the laws enacted thereunder, 28 U.S.C. =A7 2241. Mr. = New's=20 sentence does not include incarceration; he was sentenced to a bad = conduct=20 discharge only. Once Mr. New's last military appeal is concluded, = arguably, he=20 could be considered to no longer be in the custody of the military if = his=20 sentence is affirmed by military authorities; yet he would continue to = suffer=20 the stigma of a bad conduct discharge without the certainty of having = his=20 constitutional claims ruled on by an Article III court via a habeas = petition.=20 Under the Army's theory of the case, by not having incarcerated Mr. New, = and=20 then arguing comity to avoid habeas review at this time, the Army could = be=20 attempting to manipulate circumstances so as to avoid an Article III = court's=20 review of Mr. New's bad conduct discharge and the important = constitutional=20 issues he raises about the authority of the Army to issue the very = orders Mr.=20 New is challenging.

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