UNITED STATES DISTRICT
COURT MIDDLE DISTRICT ___________
UNITED
STATES OF
AMERICA
vs.
Case
No. _________________ DEFENDANT ___________________________/
MOTION TO DISMISS
COMES NOW
the defendant, by and through his undersigned attorney and asks the Court to
dismiss the indictment in this cause pursuant to Federal Rule of Criminal
Procedure 12 and gives as cause therefore the following:
OUTRAGEOUS
GOVERNMENT CONDUCT
That the indictment resulted from
outrageous government conduct constituting a deprivation of due process under
the Fifth and Fourteenth Amendments of the United States
Constitution. That Defendant is charged with one count of
possession with intent to distribute cocaine base. According to the government,
an adult agent of the government purchased the contraband from the defendant
after the government initiated the transaction and under the agent's own
volition (without being forced or threatened to do so).
Though it is not a per se due process violation to convict a defendant for
a drug offense where it is the government that initiates the alleged criminal
activity and where the government either purchases or supplies the drug, which
party initiates the alleged crime is relevant and important in assessing the
degree of government involvement in setting up the crime. Hampton v.
United States, 425 U.S. at 491, 96 S.Ct. at 1650 (Powell, J., concurring);
United States v. Gonzalez-Benitez, 537 F.2d 1051, 1055 (9th Cir.), cert. denied,
429 U.S. 923, 97 S.Ct. 323, 50 L.Ed.2d 291 (1976). Cf. United States v. Rueter,
536 F.2d 296 (9th Cir. 1976). The extent of a Defendant's
prior criminal involvement, though not dispositive, is relevant to the issue of
outrageous conduct and whether the defendant or the government should ultimately
be held accountable for the instigation of the crime. United States v.
Russell, 411 U.S. 423, 93 S.Ct. 1637, 36 L.Ed.2d 366 (1973); United States v.
Wylie, 625 F.2d 1371, 1374 (9th Cir. 1980), cert. denied, ---- U.S. -----, 101
S.Ct. 863, 66 L.Ed.2d 804 (1981). In United States v.
Russell, 411 U.S. 423, 431-32 (1973), Justice Rehnquist, writing for a majority
of the Court, noted that someday the Court might be presented with a situation
"in which the conduct of law enforcement agents is so outrageous that due
process principles would absolutely bar the government from invoking judicial
process to obtain a conviction." This was the first time the Supreme Court
officially recognized what is now commonly known as a due process defense based
on governmental overreaching and outrageous misconduct. Although Justice
Rehnquist's statement in Russell is essentially dicta, after the Court's
decision in Hampton v. United States, 425 U.S. 484 (1976), it was clear that a
majority of the members of the Court believed that the Due Process Clause could
be invoked as a ground for the dismissal of criminal charges where governmental
involvement in the criminal activities being prosecuted reached "a demonstrable
level of outrageousness." In Sorrells v. United States,
287 U.S. 435 (1932) and Sherman v. United States, 356 U.S. 369 (1958), the Court
recognized and sought to delineate the contours of the entrapment defense. In
Sorrells, a government prohibition agent appealed to the sentiments of a
"comrade in arms in the World War" (Sorrells) and successfully induced him to
sell illicit whiskey. Sorrells was promptly arrested and convicted of this
offense. Sorrells was the first case in which the Supreme Court upheld the
validity of an entrapment defense. Later in Sherman, the Court set forth what is
now known as the subjective theory of entrapment. After noting that the Court
firmly recognized the defense of entrapment, Chief Justice Warren, writing for
the majority, stated: "The function of law enforcement is the prevention of
crime and the apprehension of criminals. Manifestly, that function does
not include the manufacturing of crime. Criminal activity is such that stealth
and strategy are necessary weapons in the arsenal of the police officer.
However, a different question is presented when the criminal design originates
with the officials of the Government, and they implant in the mind of an
innocent person the disposition to commit the alleged offense and induce its
commission in order that they may prosecute." Id at 372 (quoting in part
Sorrells, 287 U.S. at 442). The question of whether the
involvement of government agents rises to the level of outrageous governmental
conduct is a question of law for the court to determine. United States v. Citro,
842 F.2d at 1152-3; United States v. Bogart, 783 F.2d at 1431; United States v.
Ramirez, 710 F.2nd 535, 539 (9th Cir. 1983); United States v. McQuin, 612 F.2d
at 1197; United States v. Prairie, 572 F.2d at 1319. The issue may properly be
raised and decided by a pretrial motion to dismiss the indictment under Fed. R.
Crim. P. 12(b). United States v. Batres-Santolino, 521 F. Supp. 744 (N.D. Cal.
1981); see also United States v. Duncan, 896 F.2d 271, 274 (7th Cir. 1990)
(outrageous government conduct claim must be made by pretrial motion). In
Batres-Santolino, the court conducted an evidentiary hearing after which it
dismissed the indictment on due process grounds. Other courts have decided to
defer ruling on the pretrial motion until after trial. United States v.
Marcello, 537 F. Supp. 402 (C.D. Cal. 1982); Although there has been some
suggestion that the nature of the police conduct could be submitted to the jury,
it appears that the trial court should make the determination. United States v.
Twigg, 588 F.2d at 379 n.8; United States v. Johnson, 565 F.2d 179,181 (lst Cir.
1977), cert. denied, 434 U.S. 1075 (1978). On appeal, the
issue of whether the government's conduct violated the defendant's due process
rights is reviewed de novo because the issue presents a question of law. United
States v. Emmert, 829 F.2d at 810; United States v. Stenberg, 803 F.2d at 428
n.6 (citing Bogart, 783 F.2d at 1431). The court will view the evidence in the
light most favorable to the government, and will accept the district court's
factual findings unless they are clearly erroneous. Emmert, 829 F.2d at 810-11
(citing Bagnariol, 665 F.2d at 880). The targeting of a
defendant is sometimes an issue. In United States v. Luttrell, 923 F.2d
764 (9th Cir. 1991) (en banc), an en banc panel of the Ninth Circuit vacated
that part of a three-judge panel ruling which had held that the government must
have "reasoned grounds" based on the due process clause to investigate an
individual. It joined four sister circuits which also rejected such a test. Id.
at 764 (citing the District of Columbia Circuit and the Tenth, Third, and Second
Circuits). The Eighth Circuit, in United States v. Jacobson, 893 F.2d 999 (8th
Cir. 1990), rev'd on other grounds, 112 S.Ct. 1535 (1992) held to the contrary,
requiring that the government show reasonable suspicion, based on articulable
facts, to justify targeting an individual for an undercover sting
operation. The government has always argued that it has
the right to lie and commit crimes in order to prosecute honest people engaged
in non-violent intercourse with consenting adults. The courts have
generally agreed. However, cases opposing outrageous government
conduct and/or entrapment may have a new vitality in light of Lawrence v.
Texas, 2003 U.S. LEXIS 5013,*;123 S. Ct. 2472; 156 L. Ed. 2d 508;71 U.S.L.W.
4574 (2003). According to Lawrence, U.S. adults have a privacy right
to engage in certain consensual nonviolent intercourse. In this case the
allegation involves economic intercourse in the privacy of a motel
room. According to the U.S.
Supreme Court, it would be unconstitutional for a defendant to be arrested for
committing (or agreeing to commit) sodomy with an undercover law enforcement
officer (LEO). According to Lawrence, it is no business of the U.S.
government or any government whether U.S. citizens do engage in sodomy.
How can Lawrence deny that U.S. citizens also have the right to recreate with
drugs? Perhaps at the same time as having sex. If the officer had
performed a sodomy "sting" operation (similar to a prostitution sting but for
the sake of argument let's say it was non-commercial) and the officer had gone
to a hotel room and tempted a defendant into engaging in sodomy with the
officer, and at the same time had used drugs, and then before leaving the
officer had purchased some drugs to take, then that scenario showcase the legal
arguments presented here. Before Lawrence, LEO's probably could have
attempted to make sting arrests for sodomy (and why they didn't try it is an odd
question itself. Would they have tried a reverse-sting or a regular
sting?). After Lawrence, sodomy with a LEO in the privacy of a hotel room
is no longer prosecutable (whether the act is merely agreed to or
completed). The same argument should apply regarding drug charges under
the same circumstances.
THE 100 TO 1 COCAINE BASE SENTENCING
RATIO
The Court should dismiss the charge because the
"cocaine base" laws are ambiguous and should be invalidated under the rule of
lenity or equal protection principles. In United States v.
Sloan, et al., 97 F.3d 1378, (11th Cir. , 1996), the appellate Court
declined to adopt the reasoning of United States District Judge J. Owen
Forrester's decision in United States v. Davis, 864 F. Supp. 1303 (N.D. Ga.
1994), and provided the basis for affirming a challenge similar to the one
argued here. The Sloan decision mis-characterizes the
issue at hand. This is not a challenge to the difference between "powder" and
"crack." Those terms are not found in the statute. In order to understand this
issue, one must first recognize that cocaine is not the same thing as cocaine
hydrochloride, the most common cocaine powder. Even the Sloan opinion
recognizes: cocaine hydrochloride powder is a cocaine salt--a mixture of
"cocaine" (C17-H21-N04) and hydrochloric acid (HCl). Cocaine (C17-H21-N04) is a
base, and is the same thing as "cocaine base." (also C17-H21-N04). It is
identical in every way. Even the Government now acknowledges that these two
substances are chemically indistinguishable. The essence
of the Davis opinion thus was simple. Congress created two different penalties
for the same chemical substance - "cocaine base" and "cocaine." Because two
different penalties apply equally to the substances in this case --which could
be categorized equally as either "cocaine" or "cocaine base"- a defendant would
deserve the lesser of two applicable penalties. The same would be true if
one penalty existed for possessing "automatic weapons" and another for
possessing "machine guns," or if driving under the influence of "hard liquor"
gave one penalty, and driving under the influence of "distilled spirits" gave
another. The issue is not what Congress may have meant to pass. The issue
is what it did pass. Looking at these words the President signed into law, even
the Sloan opinion concedes "some facial ambiguity," and acknowledges that "[n]o
doubt Congress could have enacted a statute which expressed its intentions more
precisely." Nevertheless, Sloan based its opinion on the "motivating policies
underlying" the statute, and referred repeatedly to what "Congress
intended." As the Supreme Court has stated repeatedly,
"[b]ecause construction of a criminal statute must be governed by the need for
fair warning, it is rare that legislative history or statutory policies will
ever support a construction of a statute broader than that clearly warranted by
the text." Ratzlaf v. United States, 114 S. Ct. 655, 662 (1994) (majority
overrules 10 of 11 Circuits). Notwithstanding this admonition, Sloan here
relied exclusively on these same statutory policies and legislative histories to
support its analysis. As Judge Forrester noted in his
Davis opinion, the "cocaine base" laws thus would violate equal protection
guarantees even if they somehow survived the rule of lenity. 864 F. Supp.
at 1309, n. 25. As an analogy, if sugar were illegal, it would be as if
sugar cubes were punished 100 times more harshly than granulated sugar.
Judge Forrester's conclusion is consistent with the Sentencing Commission's
recent amendments, which suggest ending the "cocaine base" distinction, in part
because "[c]rack and powder cocaine are pharmacologically the same drug."
U.S.S.G. 1995 Proposed Amendment 5. No rational basis exists for penalizing
chemically equivalent, equally smokeable substances differently.
The Court should dismiss the charges on the grounds
that the federal government's "war on drugs" is constitutional, especially where
a mandatory minimum sentence is imposed based on an indictment that did not
allege the defendant's prior record, and where the accused is now violently
incarcerated for non-violent economic activity with a consenting adult in the
privacy of a motel room within a single state.
APPRENDI ISSUE: The indictment violates Apprendi by enhancing defendant's
sentence based on prior convictions not alleged in the indictment. The Supreme
Court concluded in Almendarez-Torres v. United States, 118 S.Ct. 1219, 1232-33
(1998), that an indictment for illegal reentry did not have to include a
defendant's conviction for a prior aggravated felony for a district court to
impose an enhanced sentence under 8 U.S.C. § 1326(b)(2). The Supreme Court
subsequently determined in Apprendi v. New Jersey, 120 S.Ct. 2348, 2362-63
(2000), that "[o]ther than a prior conviction, any fact that increases the
penalty beyond the prescribed statutory maximum must be submitted to a jury, and
proved beyond a reasonable doubt" Apprendi, 120 S.Ct. at
2362-63. The Supreme Court indicated in Apprendi that its
decision in Almendarez-Torres might be called into question, but it specifically
decided not to address the issue. Id. at 2362. The Eleventh Circuit Court of
appeals has concluded that "Almendarez-Torres remains the law until the Supreme
Court determines that Almendarez-Torres is not controlling precedent." United
States v. Guadamuz-Solis, 232 F.3d 1363, 1363 (11th Cir. 2000); see also United
States v. Thomas, 242 F.3d 1028, 1034-35 (11th Cir.) (applying Guadamuz-Solis to
affirm denial of Apprendi challenge to sentence enhanced pursuant to 18 U.S.C. §
924(e)(1)), cert. denied, 121 S.Ct. 2616 (2001). Because Almendarez-Torres
is still controlling law, the Eleventh Circuit Court of Appeals has upheld
concurrent life sentences based on prior cocaine convictions that were neither
pled in the indictment nor found by the jury.
JURY
NULLIFICATION OF MANDATORY MINIMUMS: Related to the Apprendi issue is that, even
though the government has not pled, and no jury will presumably find, any prior
record, the Defendant hereby moves for a bifurcated trial regarding his prior
record and to argue jury pardon/nullification. In the
types of cases alleged here (whenever there is audio and/or video tape evidence
and the testimony of an undercover law enforcement officer in a hand-to-hand
transaction) the government often characterizes the evidence as overwhelming,
even suggesting that there is no serious defense against the facts, only absurd
defenses. In such cases, and if this is one of those cases, then there is
only one trial defense left: That the law is unjust and should be rejected by
the jury (the jury pardon or nullification defense). The Defendant should
have the right, should he so decide, to present a pardon/nullification defense,
either alone or in conjunction with any other defense.
Recent case law indicates that it is ineffective assistance of counsel for
an attorney to admit a defendant's guilt to a jury. In cases where the
government's evidence cannot be rationally disputed, and where the law prevents
the nullification defense, then the law forces defendants to mount
irrational/absurd defenses, or no defense at all. Such predicaments are a
violation of a defendant's right to due process and of a defendant's right to a
meaningful jury trial. At the very least, the jury
should be informed of the penalty in this cause, and it should be possible to
argue to the jury that the penalty is also an independent basis for acquittal.
In cases involving crimes of violence and theft, the
pardon/nullification defense is rejected by jurors because crimes of violence
and theft violate the NAP (the Non-Aggression Principle), which is a basic moral
concept to many jurors and to some judges (see e.g. Lawrence v. Texas, 2003 U.S.
LEXIS 5013,*;123 S. Ct. 2472; 156 L. Ed. 2d 508;71 U.S.L.W. 4574 (2003)).
But this is a case that does not allege violence or theft, it is a drug case,
and drug cases are in that league of cases where the nullification defense has
potential because the NAP is attractive to some jurors and judges.
In the former Soviet Union under Stalin it was said that
"the accused was given a trial but no defense." If the government has the
power to prevent a defendant from arguing that the law is wrong, then the
government has the power to prevent the defendant from having any defense
whatsoever, because the government can legislatively deprive the defendant of
every other defense. The so-called "strict liability," laws are one
example. Many drug cases are also examples.
Witchcraft was illegal in the U.S. and still is illegal in other parts of
the world. Our criminal justice system would not allow anyone to argue to
a jury that a witchcraft law should be rejected because witches do not cast
spells that make children fall into fits. Jurors would be instructed to
determine the facts based on the testimony and to follow the law, just as they
did in the Salem Witch Trials. And a defendant would be sentenced to
life in prison or even to death. Some people incorrectly
argue that for any defendant to argue that drugs should be legal under any
circumstances, is a foolhardy defense. But those arguments are made by people
who make sure the public never hears the comparison of modern prohibition to old
prohibition, and the similar corruption, violence, and irresponsible behavior
that is caused by the government, and perpetrated and perpetuated by the
government. Some defendants are deprived not only of their
only defense, they are deprived of the best defense. It might be the best
defense because it is the defense that the government has already abjectly lost
in old prohibition, and that the government has already arguably abjectly lost
in modern prohibition, though the government persists in digging its hole ever
deeper. Today, defendants are charged under modern prohibition, and the
government prevents them from presenting the exculpatory proof that has already
been established under old prohibition. Most case law
rejects the right to present a jury pardon/nullification defense. However, U.S.
v. Datcher, 830 F. Supp. 411 (M.D. Tenn. 1993), cites the political history of
jury nullification, and Datcher held that the defendant was entitled to argue
the issue of punishment to the jury, which the defendant argued was draconian,
hoping the jury would deem the penalty too great and thus acquit pursuant to
power of jury nullification. The court based its ruling on the importance
of allowing the jury "to decide whether a sentencing law should be nullified."
Id. at 412.
CRUEL AND UNUSUAL PUNISHMENT: The sentence
that is possible in this case is unconstitutional because it is cruel and
unusual punishment in permitting a mandatory minimum sentence against a man
accused of economic activity with a consenting adult in the privacy of a motel
room within a single state. The Eighth Amendment provides
that "[e]xcessive bail shall not be required, nor excessive fines imposed, nor
cruel and unusual punishments inflicted." U.S. Const. amend. VIII. Some
cases hold that in non-capital cases, the Eighth Amendment encompasses, at most,
"only a narrow proportionality principle." United States v. Brant, 62 F.3d 367,
368 (11th Cir. 1995) (relying on Harmelin v. Michigan, 111 S.Ct. 2680 (1991)). A
reviewing court must make a threshold determination that the sentence imposed is
grossly disproportionate to the offense committed. Id. If it is grossly
disproportionate, the court must then consider sentences imposed on other
persons convicted in the same jurisdiction and sentences imposed for the
commission of the same crime in other jurisdictions. Id.
In Harmelin, the Supreme Court concluded that "[s]evere, mandatory
penalties may be cruel, but they are not unusual in the constitutional sense,
having been employed in various forms throughout our Nation's history." See
Harmelin, 111 S.Ct. at 2701-02 (life sentence based on state law not "cruel and
unusual" just because it was mandatory). Following this reasoning, the Eleventh
Circuit has rejected the argument that the provisions for mandatory life
sentences under cases involving 21 U.S.C. § 841 violate the Eighth Amendment.
See United States v. Willis, 956 F.2d 248,251 (11th Cir. 1992). The Supreme
Court recently has similarly denied Eighth Amendment challenges to sentences of
25 years' to life imprisonment imposed on defendants with prior convictions who
committed theft offenses, concluding that the impact of recidivism was an
adequate reason to impose the sentences. See Ewing v. California, 123 S.Ct.
1179, 1189-90 (2003); Lockyer v. Andrade, 123 S.Ct. 1166, 1175
(2003). In Lockyer, an appeal from the Ninth Circuit's
grant of habeas relief under 28 U.S.C. § 2254, the Supreme Court concluded that,
although the Supreme Court's precedents in non-capital challenges to sentences
under the Eighth Amendment have not been "a model of clarity," that a gross
disproportionality principle is applicable to sentences for terms of years is a
"clearly established" principle and that the gross proportionality principle
"reserves a constitutional violation for only the extraordinary case." See
Lockyer, 123 S.Ct. at 1173-75. The defendant argues that,
unlike cases involving violence or theft as in Ewing and Locker, the allegations
against the defendant involve no theft or violence, and involve consensual
conduct between adults in the privacy of a motel room, and therefore defendant's
case fulfills the gross proportionality principle that "reserves a
constitutional violation for only the extraordinary case" under Lockyer.
The defendant's argument is further bolstered by Lawrence
v. Texas, supra, and it's recognition of special constitutional rights involving
non-violent private acts between consenting adults, and evolving standards of
decency. It is indecent for the government to initiate violence against a
non-violent man via a minimum mandatory sentence of life
imprisonment. The defendant's case is unusual because
mandatory minimums are unusual, especially for non-violent people, and
they are also unusual because they unconstitutionally deprive and limit the
power of the judiciary in sentencing, the separation of powers, especially where
it imposes a mandatory sentence (as here). The mandatory minimum is much
more unconstitutionally "unusual" for the federal courts than for state courts,
and especially where the federal government continues to make new (and
unconstitutional) forays into every "crime" in the country in addition to
education, healthcare, social security, medicinal drug uses, national pledges
written and edited by Congress, etc., in short: authoritarian socialism that was
never allowed by the Constitution. The mandatory
minimum of life imprisonment deprives sentencing judges of their discretionary
role afforded to the judiciary under the Constitution. Prosecutors are allowed
to determine sentences, which means they take on judicial powers that rightfully
rest with the court.
LAWRENCE V. TEXAS: On June 26,
2003, the decision issued in Lawrence v. Texas, 2003 U.S. LEXIS 5013,*;123 S.
Ct. 2472; 156 L. Ed. 2d 508;71 U.S.L.W. 4574 (2003);
http://supct.law.cornell.edu/supct/html/02-102.ZS.html http://www.supremecourtus.gov/opinions/02pdf/02-102.pdf
A sentence of violent imprisonment and the denial of any motion for
downward departure should be unconstitutional under Lawrence. The motions
above regarding the constitutionality of the charges, jurisdiction,
and Apprendi v. New Jersey, 530 U.S. 466, 120 S.Ct. 2348 (2000) etc., are also
enhanced and relevant in light of the Lawrence decision.
The Defendant's so-called criminal behavior was non-violent private
behavior among consenting adults in a motel room. Each
person has the right to do as he wishes so long as he doesn't use violence or
theft against others. Each person has the right to defend himself
against violence and theft. The purpose of government is to protect people
and their property from violence and theft --to do what people have the right to
do themselves in self-defense. When the government strays from its proper
purpose it becomes the violent violator of rights, the perpetrator of violence
and theft. And that is what the government did in this case to the
defendant. Government at all levels is slowly beginning
to understand fundamental concepts of liberty, albeit in very limited
ways. On July 4, 2003, Superior Court Judge Richard Savell of Fairbanks
Alaska dismissed Scott A. Thomas' marijuana conviction, ruling that the Alaska
Constitution guarantees the right to possess marijuana for personal use in the
home.
http://www.adn.com/alaska/story/3410510p-3440920c.html http://www.cannabisnews.com/news/thread16912.shtml
Next, there is the following opening paragraph in Lawrence from Justice
Kennedy's majority opinion: "Liberty protects the person from unwarranted
government intrusions into a dwelling or other private places. In our tradition
the State is not omnipresent in the home. And there are other spheres of our
lives and existence, outside the home, where the State should not be a dominant
presence. Freedom extends beyond spatial bounds. Liberty presumes an autonomy of
self that includes freedom of thought, belief, expression and certain intimate
conduct." (Lawrence,
http://www.supremecourtus.gov/opinions/02pdf/02-102.pdf page
1). As Scott McPherson said in a column at the "Future of
Freedom Foundation" http://www.fff.org/comment/com0307k.asp "An improvement
could certainly be made, specifically by adding "or anything else that does not
violate the rights of another person" at the end, but to say the least, it ain't
a bad start. And note Justice Kennedy's reference to the American tradition of
government, which places the individual on a plane above the state and limits
government's domain over individual preferences. Many of McPherson's
comments are repeated herein. The Lawrence opinion
continued, "It suffices for us to acknowledge that adults may choose to enter
upon this relationship in the confines of their homes and their own private
lives and still retain their dignity as free persons." (page 6) and "The State
cannot demean their existence or control their destiny by making their private
... conduct a crime. Their right to liberty under the Due Process Clause gives
them the full right to engage in their conduct without intervention of the
government. 'It is a promise of the Constitution that there is a realm of
personal liberty which the government may not enter.' [the word "sexual" removed
for emphasis] (at page 18). The words make an excellent
libertarian argument, lay a brilliant philosophical foundation, and easily
open the door for greater future expansions of personal and economic freedom and
the nullification of the "intervention of the government" in the ability of free
men and women to "control their destiny."
COMMERCE
CLAUSE AND TENTH AMENDMENT: Combining the reasoning of Lawrence with the
commerce clause, the court should conclude that the "war on drugs" by the
national government is unconstitutional. The
defendant contends that his indictment violates the Commerce Clause and the
Tenth Amendment because § 841(a)(1) is not rationally related to an express
Congressional power. The Tenth Amendment provides that "[t]he powers not
delegated to the United States by the Constitution, nor prohibited by it to the
States, are reserved to the States respectively, or to the people." U.S. Const.
amend. X. Because the Tenth Amendment does not operate on the valid exercise of
powers delegated to Congress by the Commerce Clause, no violation of the
Amendment occurs if Congress's passage of an act was a valid exercise of those
powers. United States v. Lopez, 459 F.2d 949, 951 (5th Cir.
1972)2 The Commerce Clause states that "[t]he Congress
shall have the power...[T]o regulate Commerce with foreign Nations, and among
the several states and with the Indian Tribes." U.S. Const. art 1, § 8, ci. 3.
The Supreme Court has concluded that Congress, pursuant to this clause,
permissibly may regulate (1) the use of the channels of interstate commerce; (2)
the instrumentalities of interstate commerce, or persons or things in interstate
commerce, even if the threat may derive only from intrastate activities; and (3)
activities with a "substantial relation to interstate commerce." United States
v. Lopez, 115 5.0. 1624, 1629-30 (1995). The Eleventh
Circuit has held that "possession and sale of illegal drugs impacts upon
interstate commerce," see United States v. Bernard, 47 F.3d 1101, 1103 (11th
Cir. 1995), and that Congress "has authority under the Commerce Clause to
criminalize and punish drug-related activity," see United States v. Jackson, 111
F.3d 101, 102 (11th Cir. 1997). The Former Fifth Circuit concluded that Congress
acted within its power under the Commerce Clause in enacting 21 U.S.C. §§
841(a)(I) and 846. See Lopez, 459 F.2d at 953. (In Bonner v. City of Prichard,
Ala., 661 F.2d 1206,1207(11th Cir. 1981) (en banc), the Eleventh Circuit adopted
as binding precedent the decisions of the Fifth Circuit rendered prior to 1
October 1981). The Commerce Clause argument should hold in
the defendant's favor by reconsidering Lopez coupled with
Lawrence. It took a constitutional amendment to enact
alcohol prohibition. But there has never been a constitutional amendment
allowing the federal war on drugs, and that is because citizens have become so
used to the expansion of the federal government. It would have been
unconstitutional for the federal government to enact alcohol prohibition without
a constitutional amendment and it is unconstitutional for the federal government
to have enacted the war on drugs (and the statute herein) without a
constitutional amendment. In Lopez, the Supreme
Court majority held that the Gun-Free School Zones Act of 1990 [18 U.S.C. §
922(q)(1)(A)], which forbids "any individual knowingly to possess a firearm at a
place that [he] knows...is a school zone," exceeds Congress' Commerce Clause
authority. In affirming the Fifth Circuit decision to invalidate § 922(q)
and reverse the defendant's conviction, the majority stated, "To uphold the
Government's contentions here, we would have to pile inference upon inference in
a manner that would bid fair to convert congressional authority under the
Commerce Clause to a general police power of the sort retained by the
States. Admittedly, some of our prior cases have taken long steps down
that road, giving great deference to congressional action...The broad language
in these opinions has suggested the possibility of additional expansion, but we
decline here to proceed any further. To do so would require us to conclude
that the Constitution's enumeration of powers does not presuppose something not
enumerated...and that there never will be distinction between what is truly
national and what is truly local....This we are unwilling to
do." Lopez, concerned a 1990 federal law forbidding the
possession of firearms within 1,000 feet of a school. Lopez argued that
Congress had no power to pass such a law. The Court rejected, by a 5-to-4
vote, the argument that the law was a legitimate exercise of Congress's
constitutional power to regulate interstate commerce. Chief Justice
William Rehnquist explained that the law stretched the meaning of interstate
commerce untenably. Justice Stephen Breyer was so
upset by the Lopez ruling that he took the unusual step of reading his dissent
aloud. Syndicated columnist Joseph Sobran has observed
that "The Constitution's list of the powers of Congress has little to do with
the powers Congress actually exercises. Where does it say that Congress
can tax us to pay for things like pensions and medical plans, or housing or farm
subsidies, or a thousand other things? Why do expressions like 'federal
programs' and 'the economy,' the everyday vocabulary of our current politics,
appear nowhere in the Constitution? The answer to such puzzles lies
largely in the Commerce Clause." Many of Sobran's comments are repeated
herein. Federal Courts should exist as a check on
Congress. Alexander Hamilton first propagated this idea in The Federalist
No. 78 when he described the Court as "a bulwark against legislative
encroachment." The federal government has expanded its
powers at whim, without bothering to amend the Constitution, by citing the
Commerce Clause. In one of the earlier Commerce Clause
cases, Wickard v. Filburn, the Court ruled that an Ohio farmer who had grown
wheat on his own land, to feed his own livestock, was subject to Congress's
power over interstate commerce on the remarkable grounds that such
self-consumption, on a large scale, "exerts a substantial effect on interstate
commerce." Yet, Congress is not given power to regulate every
activity that "exerts a substantial effect on" interstate commerce; it is merely
given power to regulate interstate commerce. If the same
logic were applied to "commerce with foreign nations," Congress would have
authority to regulate any activity in, say, France that "exerts a substantial
effect" on trade with this country. Furthermore,
"regulating" trade, does not authorize BANNING trade, as has been done in this
case. In Lopez, the Supreme Court revisited earlier
errors. It has now affirmed that there are actually some things that
aren't interstate commerce and can't even be reasonably said to "affect"
interstate commerce. Congress argued, in Lopez,
that guns disrupt education, and education is necessary for productive citizens,
and productive citizens sort of cause interstate commerce so Congress should,
therefore, be able to keep guns out of schools. Lopez rejected this
argument. The opposing argument in this case will be
similar to Congress' argument in Lopez: that drugs disrupt some people's minds,
and clear minds are necessary for productive citizens, and productive citizens
sort of cause interstate commerce so Congress should, therefore, be able to ban
drugs. The Court rejected this reasoning. It is
preposterous to think that 95 percent of Congress's power should be buried in
the words "and among the several states." A sound sense of proportion
would never allow this expression, taken in isolation from the rest, to overrule
the clear sense of the whole document. In Lopez, the Supreme Court has
drawn a line against the sloppy invocation of interstate
commerce. Rehnquist quoted Madison's assurance, in The
Federalist No. 45, that the powers of the federal government under the
Constitution are to be "few and defined," leaving untouched the "numerous and
indefinite" powers remaining with the states. Madison goes on to specify
that most of those few federal powers have to do with "external objects,"
meaning foreign affairs; so that the states will deal with most domestic
matters. He points out that the more successfully the federal government
does its proper job (chiefly, averting broils abroad), the smaller the role it
will play in our daily lives. Randy Barnett, the
9th Amendment scholar and author of The Structure of Liberty, has an excellent
article, "The Original Meaning of the Commerce Clause," 68 U.Chi.L.Rev. 101
(2001), (and see http://www.bu.edu/rbarnett/Original.htm) attacking the
expansive interpretation of the clause invoked to justify so much Federal
legislation, and thanks to a grant from the Cato Institute, a libertarian
think-tank, he has a new book "Restoring the Lost Constitution: The Presumption
of Liberty." For us poor souls who have repeatedly run across the
depressing phrase in court decisions that "statutes/ordinances carry a heavy
presumption of constitutionality," it will be a nice change indeed to read of a
presumption of liberty. In "The Original Meaning of the
Commerce Clause" Barnett states "The U.S. Supreme Court, in recent cases, has
attempted to define limits on the Congress's power to regulate commerce among
the several states." While Justice Thomas has maintained that the original
meaning of "commerce" was limited to the "trade and exchange" of goods and
transportation for this purpose, some have argued that he is mistaken and that
"commerce" originally included any "gainful activity." Having examined every
appearance of the word "commerce" in the records of the Constitutional
Convention, the ratification debates, and the Federalist Papers, Professor
Barnett finds no surviving example of this term being used in this broader
sense. In every appearance where the context suggests a specific usage, the
narrow meaning is always employed. Moreover, originalist evidence of the meaning
of "among the several States" and "To regulate" also supports a narrow reading
of the Commerce Clause. "Among the several States" meant between
persons of one state and another; and "To regulate" generally meant "to make
regular" -that is, to specify how an activity may be transacted- when applied to
domestic commerce, but when applied to foreign trade also included the power to
make "prohibitory regulations." In sum, according to the original meaning of the
Commerce Clause, Congress has power to specify rules to govern the manner by
which people may exchange or trade goods from one state to another, to
remove obstructions to domestic trade erected by states, and to both
regulate and restrict the flow of goods to and from other nations (and the
Indian tribes) for the purpose of promoting the domestic economy and foreign
trade. The allegation in this case is a hand-to-hand
transaction that occurred entirely in one city in Florida between consenting
adults in the privacy of a motel room and provide no basis for jurisdiction
under the commerce clause.
FIFTH AMENDMENT
TAKINGS: 21 U.S.C. § 841(a)(1) constitutes an unlawful taking of property
by the confiscation of property that is considered contraband (cocaine, etc.),
and by the indictment's plea for forfeiture of the defendant's other property,
and by the violent abduction and imprisonment of individuals for non-violent,
consensual private behavior. The Fifth Amendment of the
United States Constitution reads: "No person shall be.......deprived on life,
liberty or property, without due process of law; nor shall private property be
taken for public use without just compensation." Richard
A. Epstein in his book "Takings: Private property and the power of Eminent
Domain" said "In Mugler v. Kansas, 123 U.S. 623 (1887), the law under attack
prohibited the operation of any brewery within the state of Kansas. The
plaintiff alleged that his brewery was constructed before the passage of the
statute, that his property was ill-suited to any other use, and that its
operation did not constitute a public nuisance." Many of Epstein's
comments are repeated herein. Justice Harlan, speaking for
the court, upheld the statute by resorting to a two-pronged argument. He
first denied that the government action was a taking because the statute did not
remove the plaintiff from the possession of his premises. But that
argument is refuted by a partial takings analysis, given that the incident of
use was impaired. The second prong is discussed infra.
The reasoning of Mugler and its progeny should be revisited and
overturned. It is doubtful that the "no taking" argument was persuasive
even to the court; if it had been, the detailed consideration of the police
power justification that followed in Mugler would not have been necessary.
In dealing with the police power, Harlan's argument was quite simply that the
legislature may take steps to control the disease, poverty, and crime held to be
the inevitable and injurious consequences of alcoholism. Missing was the
necessary constitutional analysis of whether this "public nuisance" was properly
attributable to the people effected by the law. Even today the expansive
theories of proximate causation only allow an injured party to reach the
immediate supplier of the alcohol --bartenders, social hosts, or retail
outlets-- but not the original producers. See, e.g., Vesely v. Sager, (5) Cal.3d
153, (4)86 P.2d 151, 95 Cal. Rptr 623 (1971), which allowed a party injured by a
drunk driver to maintain an action against the purveyor of the alcoholic
beverages. That decision did not allow suit against the manufacturer of
the beverages and was itself overturned by statute in California. Cal. [Bus.
& Prof.] Code 25602 (West l964, 198 Supp.). Similarly, most of the gun
cases are decided the same way, so no action can be brought against the gun
manufacturer if the gun is not itself defective. See, e.g., Martin v.
Harrington Richardson, Inc. 743 F.2d 1200 (7th Cir l984). Therefore,
allowing a legislature or Congress to designate such activities as nuisances is
to erroneously allow it to define the scope of its own powers.
Suppose, however, that the government's characterization of the
manufacture of alcohol (or the distribution of cocaine) as a nuisance is, in
fact, sound. The second prong of inquiry --whether the statute is
overbroad-- calls for analyzing whether the government's narrower means would
achieve substantially the same end. In particular, the Mugler court (and
today's courts) never asked whether limitations upon the purchase or consumption
of alcohol (or cocaine) --be it by age, place of service, or condition of user--
might have done away with a large portion of the alleged social problem without
the enormous restrictions imposed upon Mugler's (or any supplier's)
operations. Likewise, the court (and today's courts) never asked whether a
more stringent set of penalties against drunkenness (or cocaine intoxication or
addiction) per se, or against offenses committed by persons in such
condition(s), could have achieved the same effect (nor asked is whether
prohibitory laws cause and increase the problems, as with alcohol
prohibition). The answers to these questions, of course, are argued both
ways, but it is difficult to believe that the blanket prohibition against the
manufacture of alcohol (or cocaine), could have been sustained when the
government had not even explored lesser restrictions upon the sale and
distribution of alcohol (or cocaine). If the government must justify its
undisputed taking of property (in this case, allegedly cocaine and the
forfeiture of any defendant's other property), then the decision seems wrong,
but if not wrong, then surely at the outer limits of the police
power.
NINTH AMENDMENT: 21 U.S.C. § 841 (a)(1)
constitutes a violation of the Ninth Amendment. "The
enumeration in the Constitution of certain rights shall not be construed to deny
or disparage others retained by the people." U.S. Constitution, Amendment
IX. Although the Ninth Amendment obviously was intended to
warn courts that citizens have rights that are not enumerated in the Bill of
Rights or the Constitution, this amendment also has been virtually read out of
the Constitution, although scholarly work in this area has awakened renewed
interest in the Ninth Amendment. Defendant argues that, considered in light of
Lawrence, the time is right for a Ninth Amendment challenge to federal drug
laws. The Ninth Amendment challenge also bolsters defendant's other
constitutional arguments in that the Ninth Amendment further shows the great
limits intended for federal action, and how far the federal government has
strayed therefrom.
DEFENDANT DENIED SIXTH AMENDMENT RIGHT TO
IMPARTIAL JURY & TO EXCLUDE JURORS EDUCATED IN GOVERNMENT
SCHOOLS The Defendant cannot obtain an impartial jury due
to the fact that some, if not all, jurors will have been educated in government
schools and cannot be impartial. The Sixth Amendment reads "In all
criminal prosecutions, the accused shall enjoy the right to a speedy and public
trial, by an impartial jury....." When the U.S.
Constitution was written, most jurors received private educations, and
government schools, if they existed at all, were rare and did not predominate as
they do today. And thus the defendant would have received an
impartial jury. Of course, the defendant would not have been charged in
the first place because the libertarian concepts of "life, liberty and the
pursuit of happiness" did not create laws banning the use of cocaine.
There was no unconstitutional federal "war on drugs" and the contraband like
that alleged here could have been purchased over the counter.
If the authors of the Constitution had foreseen the government's modern
education monstrosity then the Sixth Amendment would have stated "In all
criminal prosecutions, the accused shall enjoy the right to a speedy and public
trial, by an impartial jury.....and if the government takes over the schools,
then jurors must come only from non-government schools."
Better still, the authors would have explicitly banned government schools
just as they banned government churches, in the First Amendment, stating
"Congress shall make no law respecting an establishment of religion or
education, or prohibiting the free exercise thereof; or abridging the freedom of
the speech, or of the press, or the right of the people peaceably to assemble,
and to petition the Government for a redress of grievances. Nor suppressing such
through an establishment of religion or education." The
separation of school and state is as important as the separation of church and
state. And for the same ideological reasons.
The Constitution is supposed to limit the government and enumerate its
clauses, and no where in the Constitution do the words "schools" "education" nor
"War on Drugs" or any part thereof appear. Yet, the
government takeover and destruction of schools began in the middle 1800's
according to John Taylor Gatto, a former New York state (public) Teacher of the
Year, who started to develop this thesis in his slim but estimable 1992 volume
"Dumbing Us Down: The Hidden Curriculum of Compulsory Schooling." Now he's
returned with a massive and far better-developed follow-up, the 400-page
"Underground History of American Education," subtitled "A Schoolteacher's
Intimate Investigation Into the Problem of Modern Schooling" ($34 postpaid,
Oxford Village Press, 725 McDonough Road, Oxford, N.Y. 13830.) The
syndicated columnist Vin Suprynowicz wrote about Mr. Gatto and many of his
remarks about Mr. Gatto appear below. "By 1840"
(more than a decade before the opening of the first tax-funded government
schools on the modern model, in Massachusetts) "the incidence of complex
literacy in the United States was between 93 and 100 percent. ... In Connecticut
only one citizen out of every 579 was illiterate and you probably don't want to
know, not really, what people in those days considered literate; it's too
embarrassing. Popular novels of the period give a clue: 'Last of the Mohicans,'
published in 1818, sold so well a contemporary equivalent would have to move 10
million copies to match it. If you pick up an uncut version you find yourself in
a dense thicket of philosophy, history, culture, politics, geography, astute
analysis of human motives and actions, all conveyed in data-rich periodic
sentences so formidable only a determined and well-educated reader can handle it
nowadays. Yet in 1818 we were a small-farm nation without colleges or
universities to speak of. Could those simple folk have had more complex minds
than our own? Gatto states: "By 1940 the literacy figure
for all states stood at 96 percent for whites. 80 percent for blacks. Notice for
all the disadvantages blacks labored under, four of five were still literate.
Six decades later, at the end of the 20th century, the National Adult Literacy
Survey and the National Assessment of Educational Progress say 40 percent of
blacks and 17 percent of whites can't read at all. Put another way, black
illiteracy doubled, white illiteracy quadrupled," despite the fact that "we
spend three or four times as much real money on schooling as we did 60 years
ago." And Mr. Gatto knows why. Gatto's historical research
tells him none of this is an accident - public school pioneers like Horace Mann
found the regimented system they were looking for when they visited Prussia in
the 1840s, importing wholesale a scheme to tame and regiment what they saw as
America's dangerously anarchist new immigrant working class, training the young
of this underclass to report to a central government facility as soon as they
were old enough to use the latrine, there to be trained to all hold identical
shallow, memorized opinions and to march around to the sound of
bells. Yes, some basic literacy and numeracy would be necessary for
them to fill their intended roles in the army and in the factories ... but not
too much, and certainly not the kind of critical and analytic skills which might
lead them to question their new government bosses. Now
back to the point of this motion: Because the authors of the Constitution did
not foresee and ban government schools, jurors spend twelve years or more years
educated in government schools to obey the government, and they are subjected to
government propaganda (e.g. the movie "Reefer Madness," the "Say NO to drugs"
campaign, and superbowl ads that blame drug users for terrorism, etc.).
Not only have these jurors been educated in government
schools to obey the government, they are given a pop quiz as they walk into the
courthouse for jury duty: "Get in line, show your photo identification (for some
reason only the Middle District demands photo ID?), put your bags on the
conveyor for X-ray and hand search, empty your pockets, step through the
magnetometer, submit to the assembly line search, lift your arms for the hand
wand, turn around. There, you passed the test. You will make a fine sheep,
err, juror, I meant." Juror response "why thank you for lavishing
your attention upon me! It makes me feel safe and special. And thanks for your
kind compliment. But it's really nothing, I'm just here to follow instructions,
to do my duty, and to hang the defendant -after a fair trial, of
course!" Of course. Government
schools, and the courthouse search procedures, prevent people who are
antithetical to government. Government schools condition students to
submit to government personnel, to government searches, to fill out government
forms, and to carry government identification. The government's assembly
line search procedures exclude people who find government searches offensive, as
well as the requirement to display identification on demand. Government no
longer teaches any proper limited role of any government, including the federal
government. Government schools teach that drug laws are good, and that
jury nullification is not on the curriculum. Then, the jury voir dire
process follows up by excluding people who somehow learned otherwise.
It is said that a prosecutor can get a grand jury to
indict a ham sandwich. It should also be said that a regular trial jury
would convict the ham sandwich, thanks to government schools. And under
the sentencing laws the judge would have to sentence the ham sandwich to a
minimum mandatory sentence in prison. The ham sandwich in this case objects to
the denial of an impartial jury and public trial. Things
haven't progressed much since the Salem witch trials. If the government
tried people for casting spells that tortured little children, trial jurors
would be seated who pledged to follow the law, they would seriously consider the
first-hand testimony presented, and convict. Witchcraft is still
illegal in some countries. Government schools create
milquetoast jurors in the same way that Cuban schools create socialists.
Government schools in the U.S. are different only in degree from schools in the
former U.S.S.R. If the defendant were tried in the former
Union of Soviet Socialist Republics by jurors from Soviet schools it would be
impossible for the defendant to argue in favor of fundamental freedoms such as
economic liberty, private property, peaceful private intercourse with other
adults, the right to run a business, to sell and buy, etc. Yet, to a
different degree, the same arguments have been quashed even in the U.S. for the
defendant.
DEFENDANT DENIED FIRST AMENDMENT RIGHT & SIXTH
AMENDMENT RIGHT TO PUBLIC TRIAL The Defendant cannot
obtain a meaningful public trial due to the fact that some, if not all, news
reporters have been educated in government schools and subjected to the same
prejudicial government influences and propaganda that deny the defendant an
impartial jury. Some jurors could actually be
from the media - a frightening thought alone. Journalists are like regular
jurors, suffering the same infirmities argued above, from a government
education. Media coverage of the
unconstitutional war on drugs is barely more enlightening than reading
Pravda. It makes a defendant's right to a public trial meaningless.
Media have made a career out of toadying the government line on the war on
drugs, repeating government propaganda, cheerleading the constant growth of
government, and destroying impartial jurors, and conditioning jurors to convict
for any "crime" that government declares. The
First Amendment states, "Congress shall make no law.....abridging the freedom of
speech, or of the press." The Sixth Amendment reads "In all criminal
prosecutions, the accused shall enjoy the right to a speedy and public
trial...." and providing the defendant his 14th Amendment rights through it's
application to the states. Congress and the states make
laws that maintain the government-school monopoly and thereby abridge the
freedom of speech, and of the press, and deny defendants their right to a public
trial. When the U.S. Constitution was written, most news
reporters received private educations, and government schools, if they existed
at all, were rare and did not predominate as they do today. And thus
the defendant would have received a meaningful public trial, even though he
would not have been charged in the first place because the media held
libertarian concepts of "life, liberty and the pursuit of happiness" and the
media did not editorialize for laws criminalizing contraband like that in this
case, that was available over the counter. If the
authors of the Constitution had foreseen the government's modern education
monstrosity then the authors would have explicitly banned government schools
just as they banned government churches, in the First Amendment, stating
"Congress shall make no law respecting an establishment of religion or
education, or prohibiting the free exercise thereof; or abridging the freedom of
the speech, or of the press, or the right of the people peaceably to assemble,
and to petition the Government for a redress of grievances. Nor suppressing such
through an establishment of religion or education."
Government schools are incompatible with free speech and press.
Government schools should be unconstitutional under the First
Amendment Even if a constitutional argument could be made
for the initial creation of some government schools, their ongoing existence is
proof of their ongoing failure to educate people to handle their own educations
without government schools. Government schools are as
unconstitutional as government instructors selecting and editing press
stories. Or if compulsory education were extended to include mandatory
government schooling into adulthood, specifically including special classes for
the media. The effect of government schools upon the
media does not end after high school or college. From the earliest age,
the government teaches students what to think, say and write, and the lessons
abridge freedom of speech and press, and the ability to seat impartial jurors
and receive a public trial. The media prove the need to
end government schools.
DEFENDANT DENIED FIRST AMENDMENT
RIGHT & THE TRIAL VIOLATES ESTABLISHMENT CLAUSE The
First Amendment states, "Congress shall make no law respecting the establishment
of religion, or prohibiting the free exercise thereof;....."
Government schools are de facto churches and
violate the establishment clause. Government schools espouse the
government's belief in itself as an omnipotent, omniscient entity with unlimited
powers (or striving fast to get there) and the ability to perform
miracles. The religion is the cult of the omnipotent state.
The Constitution is supposed to limit the
government and enumerate few purposes in its clauses, and no where in the
Constitution do the words "schools" "education" nor "War on Drugs" or any part
thereof appear. The law under which the defendant is
charged is as offensive as any "blue law" where a religious belief is imposed
upon intercourse between peaceful adults in the privacy of a motel
room. When the U.S. Constitution was written, most jurors
received private educations, often in church schools, and government schools, if
they existed at all, were rare and did not predominate as they do
today. Government, through taxation and other forms of socialism,
has forced itself into the place held historically by church
schools. If the Constitution's authors had foreseen the
government's modern education monstrosity then the Sixth Amendment would have
stated "In all criminal prosecutions, the accused shall enjoy the right to a
speedy and public trial, by an impartial jury.....and if the government takes
over the schools, then jurors must come from non-government schools."
Better still, the authors would have explicitly banned
government schools just as they banned government churches, in the First
Amendment, stating "Congress shall make no law respecting an establishment
of religion or education, or prohibiting the free exercise thereof; or abridging
the freedom of the speech, or of the press, or the right of the people peaceably
to assemble, and to petition the Government for a redress of grievances. Nor
suppressing such through an establishment of religion or education."
The separation of school and state is as important as the
separation of church and state.
CONCLUSION Based on the foregoing arguments and
authorities, the defendant respectfully submits that the indictment herein
should be dismissed. The purpose of government is to protect individuals
and their property from violence. When government strays from this purpose
it becomes the violent violator of rights. On its face, 21 U.S.C. § 841 (a)(1)
violates individual rights by the confiscation of property that is considered
contraband, and by the violent abduction and imprisonment of individuals for
non-violent, consensual behavior, in the privacy of their own homes, under
penalties that constitute cruel and unusual punishment. The indictment
should be dismissed, or the defendant should be granted bifurcated trials, the
jury should be informed of the penalty, and the defendant, if he is convicted,
should be sentenced to a non-incarcerative sentence and should be granted the
other relief requested. Respectfully
submitted, _____________________________ Rex Curry, Attorney for
Defendant Tampa, Florida rexy@ij.net