Eugene Volokh's Blog, page 2600
March 7, 2012
Unanimous En Banc on Sixth Circuit
The U.S. Court of Appeals for the Sixth Circuit has a reputation for being one of the most divided and contentious courts in the nation. Many of the courts divided opinions have been chronicled on this blog. But it's important not to overstate the degree of division on the court. Last week, for instance, the court issued a unanimous en banc decision in Chapman v. UAW Local 1005, a case considering whether a GM employee's suit against both his employer and his union was barred because of his failure to exhause his internal union remedies before filing suit in federal court. Not only were the judges unanimous in rejecting the employee's claim, they also united around a decision to overturn one of the circuit's own precedents, a 1999 decision Williams v. Molpus as "inconsistent with Supreme Court precedent and contrary to national labor policy."
Justice in Blue and Gray: A Legal History of the Civil War
Many VC readers, I know, have a keen interest in Civil War history. Over at Lawfare, senior national security lawyer at DOD and retired Navy JAG Alan G. Kaufman – who occasionally comments here at Volokh – offers a striking review-essay of Stephen C. Neff's 2010 book, Justice in Blue and Gray: A Legal History of the Civil War. The book is a fine one, and the review essay also. The review goes on to observe the ways in which the legal questions posed by the Civil War, and many of the answers then given, continue to reverberate today in our conflicts and approaches to counterterrorism. The Civil War remains the "deeper well" of American Constitutional experience in national security. From the opening:
[T]he American Civil War, much like the armed conflicts in which the United States remains involved since the events of 9/11, required that national security strategy and decision making operate "in the dual spheres of criminal law and belligerency." Today's questions of combatant status and the fate of unlawful belligerents, debates over executive powers, controversial habeas litigation, struggles over restraints on civil liberties, executive detentions, trials of civilians before military commissions, questions of whether and when to apply domestic criminal law or the international law of war, and, of course, when does the war end and what are the attendant legal consequences – all these questions figured into the law of the Civil War.
Justice in Blue and Gray, A Legal History of the Civil War, by the eminent historian of public international law and the law of war, Stephen C. Neff, is intended as "primarily a case study of the myriad ways in which law plays an important role in a crisis of giant political and military dimensions." This is a work of serious history by a leading legal historian, not a thinly-veiled parable or historical roman-a-clef for the present; it offers no direct connection to our world today, except by the reader's own inferences. Still, this legal history offers a not-so distant mirror. Clear and elegant in its language, understandable to the layman as well as to the lawyer, Justice in Blue and Grayshows how law in war can be used – indeed, was used – to accomplish strategic and operational war fighting objectives in a vast and bloody conflict. To use a word Neff does not use (and a somewhat controversial word in today's parlance), this is a study of law in the Civil War as lawfare. It would be something of an understatement to say that these understandings – both as icon from the past but also source of live legal precedent – are entirely in play in the most recent round of speeches by the Administration's senior legal officials seeking to explain itself and its justifications in Guantanamo detention, trials, targeted killing, and the targeted killing of Americans. The recent speeches by Attorney General Eric Holder, DOD General Counsel Jeh Johnson, DOS Legal Adviser Harold Koh, and others can profitably be read with this book to hand.
At the level of grand strategy, all lawfare is a battle for legitimacy. To be sure, other objectives – operational and tactical — may flow from that source, but legitimacy is always the underlying and fundamental legal objective. Thus, for the nascent Confederacy, a key initial strategic objective was recognition as a sovereign nation state, and the potentially decisive foreign alliances, particularly with Britain, that could flow from the establishment of that legitimacy. For the Union, an initial strategic objective was to prevent any such recognition and concomitant legitimacy. And so the first and richest chapter of Justice in Blue and Gray discusses the legal arguments surrounding the act of secession by the southern states. Upon the answer to these fundamental legal questions would depend not only whether the secession and a fight either to maintain it by one or to stop it by the other could be held legitimate, but also whether what followed would be law enforcement or war – and thus what measure of violence could legitimately and lawfully be taken by either side to suppress or perfect the secession.
Relative Risks of Rape by Age, and Is Rape "About Control … Not About Sex"?
A commenter on an earlier gun license thread writes:
It isn't just young, pretty women who get raped, by a long shot. Middle-aged women do get attacked, and elderly women are even more vulnerable. Rape is about control (just like disarmament) not about sex.
Yes and no. It's true that middle-aged women do sometimes get attacked, but according to the National Crime Victimization Survey (2007 data), the rate of attempted or completed rape or sexual assault is:
Age
Rate per 1000
16-19
4.9
20-24
5.9
25-34
2.4
35-49
1.8
50-64
0.3
65+
0.2
And while other crimes, such as robbery, tend to affect younger women more than older women as well, the drop-off is much less sharp than with rape.
It thus seems to me that sexual attacks on women are pretty strongly correlated with their being in the years of maximum sexual attractiveness. (Naturally, the question whether "pretty women" are more vulnerable is much harder to study than the question whether young women are more vulnerable.) This suggests to me that rape is generally both about sex and about violence and control, not just about one or the other.
Ban on "Entertaining Displays" of Sweepstakes Results Violates the First Amendment
So holds the North Carolina Court of Appeals in Hest Technologies, Inc. v. State (N.C. App. Mar. 6, 2012). An excerpt:
[Hest uses its] proprietary sweepstakes management software … to conduct promotional sweepstakes as a means of marketing their [long-distance telephone time and high-speed internet service] products at the point of sale…. A player who has received a sweepstakes entry can only reveal this predetermined result by connecting to a computer terminal on which the sweepstakes software has been loaded. Once connected, the player has the option of either (1) choosing an "instant reveal," whereby the results of the sweepstakes entry are immediately displayed on a computer screen; or (2) having the results revealed through a video game played on the computer terminal. The method by which the result is revealed does not affect the outcome of the sweepstakes. Moreover, customers retain the value of the purchased prepaid phone or internet time, regardless of the outcome of the sweepstakes….
On 20 July 2010, the North Carolina General Assembly … amended the North Carolina General Statutes to include a provision which prohibited conducting or promoting any sweepstakes which prohibited conducting or promoting any sweepstakes which utilized an "entertaining display." Plaintiffs' sweepstakes systems fell squarely within the ambit of the new N.C. Gen.Stat. § 14–306.4….
N.C. Gen.Stat. § 14–306.4 does not forbid the conducting or promotion of sweepstakes provided that the result of the sweepstakes entry is conveyed through any method other than an entertaining display…. Thus, it is the specific method of disseminating [lawful] sweepstakes results through an entertaining display that is criminalized by N.C. Gen.Stat. § 14–306.4….
[B]anning the dissemination of sweepstakes results through entertaining displays cannot be characterized as merely a regulation of conduct. Instead, that portion of N.C. Gen.Stat. § 14–306.4 which forbids "the reveal of a prize" by means of an entertaining display directly regulates protected speech under the First Amendment [and is unconstitutional.
The dissenter disagreed:
Here, N.C. Gen.Stat. § 14–306.4 does not prohibit plaintiffs from allowing a customer to play plaintiffs' video games. Rather, the statute prohibits plaintiffs from conducting or promoting their sweepstakes through the use of a video game. Plaintiffs are free to allow anyone to play their video games so long as the video games are not used to conduct or promote a sweepstakes.... [T]he statute merely regulates conduct and not speech ….
Licenses to Carry Guns, Protection Against Robbery, and Protection Against Rape
When states have (or had) discretionary gun carrying license system, they have often provided that people who engage in "business activities that involve heightened risk, such as the need to carry cash or other 'street valued' commodities" should generally get licenses. (See this post, for instance, about the Maryland scheme.) The theory is that these people are at heightened risk of robbery, and the loss to them from the robberies is likely to be especially grave. And this theory seems factually plausible. To my knowledge, no-one has quantified how great the risk tends to be, or required such an empirical showing to justify creating such a category, but it's certainly reasonable that the danger faced by someone who routinely carries lots of valuables is greater than that faced by, say, me.
But women, especially young women, are particularly likely to be targets of rape. See, e.g., table 4 of this document reporting 2008 data and table 4 of this document reporting 2007 data, reporting an aggregate approximately 0.5% per year rate of attempted or completed rape or sexual assault for women age 20 to 24. This is likely not as high as the attempted or completed robbery rate for men who carry valuables, but it might well be comparable when you multiply probability of the crime by the gravity of the damage to the victim.
In a sense, the women are transporting something that is likewise seen by some criminals as especially worth taking — their bodies. When people who carry lots of money are entitled to tools that help them protect their property (and also help them protect themselves against the death or bodily injury that may stem from attacks by robbers), why shouldn't young women be entitled to similar tools that help them protect their bodily integrity (and also help them protect themselves against the death and further bodily injury that may stem from attacks by rapists)?
Of course, I recognize that if young women are allowed to carry guns to protect themselves against rape, it will be politically difficult to avoid extending the same right to older women, and politically and constitutionally difficult to avoid extending the same right to men. Thus, the licenses given to people, mostly relatively rich and mostly men, to defend against robbery will lead to less gun carrying than licenses given to young women to defend against rape. But is that basis enough to allow the money-carriers guns to defend against a less serious crime, but to deny the young women guns to defend against a more serious crime?
District Court Concludes Second Amendment Secures Right to Carry, But Not "While Being Employed for" a Felon
So holds United States v. Weaver (S.D. W. Va. Mar. 6, 2012). The judge expressly endorsed Judge Niemeyer's separate opinion in United States v. Masciandaro (4th Cir. 2011) that concluded that the Second Amendment applies outside the home and not just in the home, and that restrictions on gun carrying must be tested under so-called "intermediate scrutiny." (For more on the dispute among courts about the right to keep and bear arms outside the home, see this post about yesterday's district court decision striking down Maryland's broad gun carry restrictions.)
But the court held that 18 U.S.C. § 922(h), which bars people from knowingly possessing guns "in the course of … employment" "while being employed for any person" who is himself a felon possessing guns. (Here, the defendants were allegedly members of the Pagans Motorcycle Club, and were allegedly taking instructions from a club leader who was a convicted felon.) Among other things, the court held that,
Section 922(h) is … limited in [important] respects: temporally, an individual is only precluded from possessing a firearm while acting in the course of his employment for a prohibited person, and he is free to regain his right to possess firearms by simply parting with the employment relationship. To be quite clear, even an individual who maintains an employment relationship with a prohibited person may lawfully possess firearms, provided he is not acting in the course of employment at the time of the firearm possession. From this discussion, it is clear that Congress tailored the prohibition in § 922(h) to cover only certain individuals at certain times and when they act in certain ways. In other words, the scope of § 922(h) is effectively limited to vicarious possession by prohibited persons, although it penalizes the proxy rather than the prohibited person. It is a commonsense extension of the prohibitions contained in § 922(g). Just as § 922(g) strips firearms from the possession of prohibited persons, § 922(h) effectively strips firearms from their control.
The court does not discuss the situation where someone is employed "for" (the statutory requirement) a person, but whose gun-related actions are not controlled by a person — for instance, if a felon contracts with a security company to provide him with a full-time bodyguard. In that situation, I would think that the bodyguard is "employed for" the felon, though not employed by the felon. Likewise, the court does not discuss what happens when § 922(h) is applied to people who are "employed for" other people who aren't themselves allowed to possess guns, such as nonresident (but legally admitted) aliens, people who have a history of mental problems, and the like. Section 922(h) applies to anyone who is "employed for" a person who is legally not allowed to possess guns himself, whether because of felony or some other disqualifying characteristic.
I would think that in many such situations the bodyguard's own Second Amendment rights — including such rights exercised in a place that the bodyguard and the protected person are using as a temporary home — should prevail, at least if the bodyguard is responsible to a security company even though he is "employed for" the company's client. But perhaps that could be avoided by construing "employed for" narrowly; in this case, the government's claim is that the defendant's gun use was indeed being controlled by the felon motorcycle club leader.
Koch v. Cato — Woodlief Responds, Frank Comments
Here are two more worthwhile posts on the Koch-Cato kerfuffle: One by Tony Woodlief responding to Jerry Taylor, the other by Ted Frank. Recognizing that not every reader of the VC is interested in this contretemps, I've placed excerpts from both posts below the jump.
[UPDATE: It appears Ted Frank's comment has been taken down. If I can locate a cached copy, I will repost it. Skip Oliva comments here.]
Tony Woodlief, one of the folks proposed as a potential Cato Institute board member by the Koch brothers, has posted a lengthy response to the comments by Jerry Taylor I posted over the weekend. It reads in part:
I didn't have a dog in this hunt. I only learned that a shareholder nominated me to the Cato Institute board after Healy, Taylor, and others publicly branded me a heretic. I am, Taylor writes, "a Republican blogger," who complains about libertarians toking up at political meetings. Healy and others dutifully repeat Taylor's charges. . . .
Now, I understand that Taylor is in a tough spot. He needs a conspiracy. Heaven forbid it be a simple contract dispute. Angels prevent that anyone who believes in liberty question why a $23 million organization doesn't have more impact on public opinion. This has to be about bad people doing secretive things in the dead of night to rob earnest and freedom-loving people of their standard-bearer.
But the thing is, when you start lifting sentences from what someone writes, intellectual honesty — not to mention plain decency — dictates that you provide context. Maybe that's old-school thinking, way back in the day when we believed in contracts and the rule of law. Maybe libertarianism is all post-modern and stuff now.
Either way, now I do have a dog in this hunt, because I'm one of the people Taylor decided to attack in his fit of self-preservation.
Keep in mind that we're talking about things I wrote ten years ago. My views have changed a bit, and any fair reading of my work will indicate as much, just as it will quickly reveal that I am neither a Republican nor a libertarian-hater. . . .
I also call libertarianism, as Taylor notes, "a flawed and failed religion posing as a philosophy of governance." (Religion? What could I have been thinking? That would imply sects and unquestionable beliefs and bitter squabbles over abstruse distinctions…)
But immediately after, I write: "The reason I will address this topic — and the reason you should care — is because libertarianism represents perhaps the best set of potential political solutions to America's problems…"
The exceedingly clear point, grasped by a wide array of libertarians and conservatives who joined the debate in the comments section of my blog, is that we have to overcome significant hurdles in order to make libertarianism a competitive alternative in the minds of voters. Now, you may disagree with that, but the fact that I believe it does not make me — unless libertarianism has been transmogrified into a church — an "anti-libertarian." . . .
I respect many thinkers associated with Cato. Hearing talks by Tom Palmer and David Boaz brought me into libertarianism as a college student. Bob Levy's work on the gradual erosion of liberty by the courts is essential, and helped me recognize how completely property rights have been stripped from the Constitution. Radley Balko has waged an almost single-handed battle to highlight police abuse, causing me to rethink my decade-old critique that libertarians are overly focused on drug legalization.
I don't know if I could mutter whatever catechism one must repeat to be accepted into the libertarian fold, but I'm certainly no enemy. The pity of it is that Jerry Taylor and other Cato leaders have no qualms about deliberately misleading people to believe otherwise. What's more, I know some of the other people they accuse of being operatives and conspirators, and these accusations ring just as false.
I assume intellectual integrity is essential to the libertarian philosophy, and if so, I wonder who is doing it more harm — someone like me, who has questioned in good faith some of its tenets, or Messrs. Taylor, Healy, and Crane, who appear for all the world like Washington, D.C. bureaucrats trying desperately to keep hold of their tenure.
Ted Frank, writing at Point of Law, also expresses some misgivings at what appears to be the strategy of the Cato Institute's current leadership in this fight. It reads in part:
Part of the problem here is that Ed Crane is pursuing a strategy that maximizes the chance that Ed Crane will stay in power without having to ever answer to the Kochs again, but at the expense of the Cato Institute. If the dispute is long and protracted, Cato will starve as funding sits on the sidelines and people wary of Crane's allegations are unwilling to do work affiliated with Cato; meanwhile, the bad-mouthing of the Kochs prevents the Kochs from exercising their contractual rights without damaging Cato's reputation. Crane's strategy has made compromise impossible, because he has announced that the Kochs are incompatible with Cato, so there is now no resolution that the Kochs can agree to short of surrender without realizing Crane's self-fulfilling prophecy of a tarnishing of Cato. That metaphorical dousing of the building with gasoline means that now the only outcome that "saves" Cato without significant damage to Cato is if the Kochs cave quickly. Even if Crane backs down from the precipice, he's done irreversible damage, because anything other than total victory by Crane—even a compromise by the Kochs to give Niskanen's shares to a mutually agreeable fourth shareholder and let Crane have life tenure—will now be perceived by the public as an agreement to Koch puppetry.
This may well be the optimal strategy for Cato if Crane correctly believes that the Kochs will damage Cato's independence. Whether that belief is true depends on whether the Koch nominations for the board of people offensive to libertarians reflected malevolence or a sloppy failure of lower-level Koch officials in trying to find board members who could be counted upon to protect the Kochs' interests in maintaining the primacy shareholder agreement against an admitted effort by Cato officials to freeze out the Kochs. . . . If Crane is making his allegations in good faith, one can reasonably then ask why, if the Kochs were so potentially destructive to the movement, Cato tolerated the sword of Damocles for so many decades instead of starting anew or warning its donors of the risk; the schadenfreude of Murray Rothbard fans is the sanest thing I've seen from that camp in years. It's thus difficult not to infer a certain level of disingenuousness in Cato's current litigation position. That position seems to be calculated to maximize the benefit to Ed Crane (either as head of Cato or head of a future hypothetical Cato-in-Exile), rather than Cato and the libertarian movement . . .
For better or worse, Crane's strategy has forced the situation into a game of chicken where what would be best for the movement is if the Kochs agree to a humiliating retreat from their legal rights. That seems an unlikely outcome: if unfair political attacks and threats of IRS audits from the Obama administration (which seems to suffer from Koch derangement syndrome far more than the Kochs suffer from Obama derangement syndrome) haven't deterred the Kochs, bad publicity from Ed Crane won't. The social deadweight loss all around makes me very sad: the world is a better place with a happy and independent and well-funded Cato Institute, and with libertarians training their sights on the dangers to personal and economic liberty rather than internecine squabbles. Like Jonah Goldberg, I want both sides to win.
Paul Campos and Deborah Rhode on Law School Costs and Debts in the Current Legal Economy
March 6, 2012
Leadership Principles of the Galactic Empire
Forbes writer Alex Knapp has an interesting article pointing out five supposed leadership mistakes made by Star Wars' Galactic Empire. I think many of these supposed mistakes turn out to be quite reasonable once you realize what the Emperor's real purposes were. Hint: Ruthless dictators don't pursue the same goals as management consultants.
Here are the five supposed errors along with my comments:
Mistake #1: Building an organization around particular people, rather than institutions.
Perhaps the biggest mistake of the Galactic Empire made is its singular focus on the preservation of power for the Emperor and a few of his chosen lackeys….
Your organization needs to be structured so that talent is being developed on all levels of the organization, in order to ensure smooth functioning and ensure that it's easy for people to rise in the organization in the event that key individuals leave.
This strikes me as a feature of the Empire rather than a bug. The whole reason why Palpatine established the Empire in the first place is precisely "the preservation of power for the Emperor and a few of his chosen lackeys." Complaining that the Empire failed to ensure that "talent is being developed on all levels of the organization" is kind of like saying that the Soviet Union would have worked better if Lenin and Stalin had established a market economy instead of communism. It ignores the whole reason why the institution was established in the first place.
Mistake #2: Depriving people of the chance to have a stake in the organization.
By consolidating his power, the Emperor didn't just ensure that his organization wouldn't survive his death. He also deprived a key motivation for both his employees and the public-at-large: a feeling of having a stake in the success of the organization. The Emperor disbanded the Galactic Senate, removing the idea of any democratic stake in the government….
The Emperor or Vader gave orders and that was it. No further discussion…
[T]his is the worst possible way to get the best work out of your employees. Fear, combined with a sense of powerlessness, only inspires the bare minimum amount of work…
Again, feature rather than bug. "Fear, combined with a sense of powerlessness" may not "get the best work out of your employees." But it's a great way to keep the ruler in power, which was the Emperor's real goal. It's a formula that has worked for numerous dictators throughout history. See Lenin and Stalin again. The trouble only begins when weak-minded fool successors like Gorbachev start listening to their management consultants and ease up on the repression. As Machiavelli put it, "it is much safer to be feared than loved, if one of the two has to make way."
Mistake #3: Having no tolerance for failure.
In an early part of the Empire Strikes Back, the Empire attempted to wipe out the Rebel Alliance once and for all in the Battle of Hoth. However, because Admiral Ozzel took the Imperial Fleet out of lightspeed too close to the Hoth system, the Rebel Alliance was able to detect the Imperial approach and quickly begin its defense. Enraged by this error, Darth Vader used the Force to choke Admiral Ozzel to death. Captain Piett, Ozzel's second-in-command, was then promoted to Admiral and given command of the Imperial Fleet.
This swift, decisive punishment of failure is a huge error of management….
Even beyond this one mistake, by adopting a management style of "failure leads to Force choking," Vader developed an organizational culture that was destined to be weak. People would be afraid to offer feedback or suggestions, choosing instead to follow orders to the letter. This ensures that decisions are made at a very high level, and anyone under those levels will lack initiative or the ability to act on their local knowledge.
Once again, this misses the point. If Vader's minions "lack initiative or the ability to act on their local knowledge," they are unlikely to try to overthrow him and the Emperor. Moreover, it's far from clear that the Imperial Fleet functioned any worse under Piett than Ozzel. The new admiral certainly had a strong incentive to succeed once he saw what the price of failure was! If he failed anyway, it was only because the plot demanded that the Rebels get away. If Vader and Piett had wiped them out in Episode V, the audience (including then-seven year old Ilya) would not have been as forgiving as Knapp seems to be.
Mistake #4: Focusing all of the organization's efforts into a single goal and failing to consider alternatives.
When it came to the success of the Galactic Empire, the Emperor had one single idea that he was absolutely obsessed with: building the Death Star. The completion of the Death Star, with its ability to destroy entire planets, was the singleminded obsession of the Emperor. At no point do we ever see any alternatives broached…
It's vital to be flexible and adaptable to changing circumstances. You should always consider alternatives to your course of action and develop multiple plans for achieving particular goals in case one or more plans don't pan out.
Actually, as I pointed out in my last Star Wars post, the Emperor's real error was in not building enough Death Stars. He clearly had the resources to build many more. And if he had, he could have crushed the rebels even if he lost a few Death Stars to lucky shots in the process. Moreover, the Emperor did in fact build up a lot of other military forces with which to suppress the Rebellion. Remember the huge fleet commanded by Ozzel and Piett, which Knapp discussed in his previous point! If not for the demands of the plot (reinforced by numerous plot-holes), the powerful imperial military would never have been defeated by a bunch of ragtag rebels aided by primitive Ewoks.
Mistake #5: Failing to learn from mistakes.
The Galactic Empire devoted years, an enormous amount of money, and an enormous amount of manpower to building the Death Star. After it was built, the Death Star only successfully completed one mission before it was destroyed by the Rebels. And the Empire's response? Build a bigger, newer Death Star to serve as a target for the Rebel Alliance. In the second case, the Death Star wasn't even completed before the Rebels managed to destroy it again.
Despite the failure of Force choking Admiral Ozzel to improve performance by the Imperial Fleet, Vader Force choked Captain Needa after his failure to capture the Millenium Falcon shortly thereafter.
Both the Emperor and Vader were obsessed with turning Skywalker to the Dark Side of the Force, even after Skywalker made it clear that he'd rather die than abandon the Rebel Alliance or join the Dark Side….
While it's admirable to not let setbacks hold you back from pursuing your goals, its vital to learn from every failure in order to correct your course of action. Failing to learn from your mistakes and repeating them will inevitably lead to the destruction of your organization.
Here, it's possible that Knapp has pointed out a real flaw in the Empire's strategy. But let's remember that in each of these cases, they failed in their first attempt only because of random coincidences and plot holes (Han Solo just happened to arrive in the nick of time in Episode IV; the Death Star was destroyed by a lucky shot just before it would have wiped out the Rebels; and so on). A good leader doesn't discard a sound strategy merely because low-probability events derail it the first time he tries it. How was Palpatine to know that the writers had it in for him to such an extent that his brilliant plan would fail the second time around because an "entire legion of [his] finest troops" was defeated by an army of stone age teddy bears? But for that ridiculous turn of events, the Death Star would – as the Emperor points out to Luke – have remained "quite operational." And the Rebels would have been wiped out. Ultimately, the great Emperor Palpatine was done in not by his own mistakes, but by the even more powerful Emperor George Lucas.
Something's Not Kosher about Davis-Bacon
That's the subtitle Reason Magazine editors gave to this journalistic piece I wrote back in 1991 about the discriminatory origins and effects of the Davis-Bacon Act. Reason recently posted it online, and I'm pleased to see that it holds up pretty well. I explored the anti-black origins of Davis-Bacon in far more detail in a chapter of my book, Only One Place of Redress.
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