Friday, April 27, 2012

McCarthyite Smith Act DeJaVu? - Terror Conviction with No Evidence of Terrorism

McCarthyite Smith Act DeJaVu? - Terror Conviction with No Evidence of Terrorism

 

A Dangerous Mind?

 

by Andrew F. March

Op-Ed

 

New York Times

April 22, 2012

 

http://www.nytimes.com/2012/04/22/opinion/sunday/a-dangerous-mind.html

 

Late last year, a jury in Boston convicted Tarek Mehanna, a

29-year-old pharmacist born in Pittsburgh, of material

support for terrorism, conspiring to provide material

support to terrorists and conspiring to kill in a foreign

country, after a 35-day trial in which I testified as an

expert witness for the defense.

 

On April 12, Mr. Mehanna was sentenced to 17 and a half

years in prison. Hearing this, most Americans would probably

assume that the F.B.I. caught a major homegrown terrorist

and that 17 and a half years is reasonable punishment for

someone plotting to engage in terrorism. The details,

however, reveal this to be one of the most important free

speech cases we have seen since Brandenburg v. Ohio in 1969.

 

As a political scientist specializing in Islamic law and

war, I frequently read, store, share and translate texts and

videos by jihadi groups. As a political philosopher, I

debate the ethics of killing. As a citizen, I express views,

thoughts and emotions about killing to other citizens. As a

human being, I sometimes feel joy (I am ashamed to admit) at

the suffering of some humans and anger at the suffering of others.

 

At Mr. Mehanna's trial, I saw how those same actions can

constitute federal crimes.

 

Because Mr. Mehanna's conviction was based largely on things

he said, wrote and translated. Yet that speech was not

prosecuted according to the Brandenburg standard of

incitement to "imminent lawless action" but according to the

much more troubling standard of having the intent to support

a foreign terrorist organization.

 

Mr. Mehanna was convicted and sentenced based on two broad

sets of facts. First, in 2004, Mr. Mehanna traveled with a

friend to Yemen for a week, in search, the government said,

of a jihadi training camp from which they would then proceed

to Iraq to fight American nationals. The trip was a complete

bust, and Mr. Mehanna returned home.

 

Some of his friends continued to look for ways to join

foreign conflicts. One even fought in Somalia. But Mr.

Mehanna stayed home, completed a doctorate in pharmacology

and practiced and taught in the Boston area. But the Yemen

trip and the actions of his friends were only one part of

the government's case.

 

For the government, Mr. Mehanna's delivery of "material

support" consisted not in his failed effort to join jihadi

groups he never found, nor in financial contributions he

never made to friends trying to join such groups, but in

advocating the jihadi cause from his home in Sudbury.

 

MR. MEHANNA'S crimes were speech crimes, even thought

crimes. The kinds of speech that the government successfully

criminalized were not about coordinating acts of terror or

giving directions on how to carry out violent acts. The

speech for which Mr. Mehanna was convicted involved the

religious and political advocacy of certain causes beyond

American shores.

 

The government's indictment of Mr. Mehanna lists the

following acts, among others, as furthering a criminal

conspiracy: "watched jihadi videos," "discussed efforts to

create like-minded youth," "discussed" the "religious

justification" for certain violent acts like suicide

bombings, "created and/or translated, accepted credit for

authoring and distributed text, videos and other media to

inspire others to engage in violent jihad," "sought out

online Internet links to tribute videos," and spoke of

"admiration and love for Usama bin Laden." It is important

to appreciate that those acts were not used by the

government to demonstrate the intent or mental state behind

some other crime in the way racist speech is used to prove

that a violent act was a hate crime. They were the crime,

because the conspiracy was to support Al Qaeda by advocating

for it through speech.

 

Much of Mr. Mehanna's speech on Web sites and in IM chats

was brutal, disgusting and unambiguously supportive of

Islamic insurgencies in Iraq, Afghanistan and Somalia. In

one harrowing IM chat, which the government brought up

repeatedly during the trial, he referred to the mutilation

of the remains of American soldiers in response to the rape

of a 14-year-old Iraqi girl as "Texas BBQ." He wrote poetry

in praise of martyrdom. But is the government right that

such speech, however repulsive, can be criminalized as

material support for terrorism?

 

In the 2010 Supreme Court decision Holder v. Humanitarian

Law Project, Chief Justice John G. Roberts Jr. declared that

for speech to qualify as criminal material support, it has

to take the form of expert advice or assistance conveyed in

coordination with or under the control of a designated

foreign terrorist organization. In that decision, Justice

Roberts reaffirmed that "under the material-support statute,

plaintiffs may say anything they wish on any topic" and

pointed out that "Congress has not sought to suppress ideas

or opinions in the form of `pure political speech.' "

Justice Roberts emphasized that he wanted to "in no way

suggest that a regulation of independent speech would pass

constitutional muster, even if the Government were to show

that such speech benefits foreign terrorist organizations."

 

On April 12, Mr. Mehanna was sentenced to 17 and a half

years in prison. Hearing this, most Americans would probably

assume that the F.B.I. caught a major homegrown terrorist

and that 17 and a half years is reasonable punishment for

someone plotting to engage in terrorism. The details,

however, reveal this to be one of the most important free

speech cases we have seen since Brandenburg v. Ohio in 1969.

 

As a political scientist specializing in Islamic law and

war, I frequently read, store, share and translate texts and

videos by jihadi groups. As a political philosopher, I

debate the ethics of killing. As a citizen, I express views,

thoughts and emotions about killing to other citizens. As a

human being, I sometimes feel joy (I am ashamed to admit) at

the suffering of some humans and anger at the suffering of others.

 

At Mr. Mehanna's trial, I saw how those same actions can

constitute federal crimes.

 

Because Mr. Mehanna's conviction was based largely on things

he said, wrote and translated. Yet that speech was not

prosecuted according to the Brandenburg standard of

incitement to "imminent lawless action" but according to the

much more troubling standard of having the intent to support

a foreign terrorist organization.

 

Mr. Mehanna was convicted and sentenced based on two broad

sets of facts. First, in 2004, Mr. Mehanna traveled with a

friend to Yemen for a week, in search, the government said,

of a jihadi training camp from which they would then proceed

to Iraq to fight American nationals. The trip was a complete

bust, and Mr. Mehanna returned home.

 

Some of his friends continued to look for ways to join

foreign conflicts. One even fought in Somalia. But Mr.

Mehanna stayed home, completed a doctorate in pharmacology

and practiced and taught in the Boston area. But the Yemen

trip and the actions of his friends were only one part of

the government's case.

 

For the government, Mr. Mehanna's delivery of "material

support" consisted not in his failed effort to join jihadi

groups he never found, nor in financial contributions he

never made to friends trying to join such groups, but in

advocating the jihadi cause from his home in Sudbury.

 

MR. MEHANNA'S crimes were speech crimes, even thought

crimes. The kinds of speech that the government successfully

criminalized were not about coordinating acts of terror or

giving directions on how to carry out violent acts. The

speech for which Mr. Mehanna was convicted involved the

religious and political advocacy of certain causes beyond

American shores.

 

The government's indictment of Mr. Mehanna lists the

following acts, among others, as furthering a criminal

conspiracy: "watched jihadi videos," "discussed efforts to

create like-minded youth," "discussed" the "religious

justification" for certain violent acts like suicide

bombings, "created and/or translated, accepted credit for

authoring and distributed text, videos and other media to

inspire others to engage in violent jihad," "sought out

online Internet links to tribute videos," and spoke of

"admiration and love for Usama bin Laden." It is important

to appreciate that those acts were not used by the

government to demonstrate the intent or mental state behind

some other crime in the way racist speech is used to prove

that a violent act was a hate crime. They were the crime,

because the conspiracy was to support Al Qaeda by advocating

for it through speech.

 

Much of Mr. Mehanna's speech on Web sites and in IM chats

was brutal, disgusting and unambiguously supportive of

Islamic insurgencies in Iraq, Afghanistan and Somalia. In

one harrowing IM chat, which the government brought up

repeatedly during the trial, he referred to the mutilation

of the remains of American soldiers in response to the rape

of a 14-year-old Iraqi girl as "Texas BBQ." He wrote poetry

in praise of martyrdom. But is the government right that

such speech, however repulsive, can be criminalized as

material support for terrorism?

 

In the 2010 Supreme Court decision Holder v. Humanitarian

Law Project, Chief Justice John G. Roberts Jr. declared that

for speech to qualify as criminal material support, it has

to take the form of expert advice or assistance conveyed in

coordination with or under the control of a designated

foreign terrorist organization. In that decision, Justice

Roberts reaffirmed that "under the material-support statute,

plaintiffs may say anything they wish on any topic" and

pointed out that "Congress has not sought to suppress ideas

or opinions in the form of `pure political speech.' "

Justice Roberts emphasized that he wanted to "in no way

suggest that a regulation of independent speech would pass

constitutional muster, even if the Government were to show

that such speech benefits foreign terrorist organizations."

 

Andrew F. March is an associate professor of political science at Yale.

 

==========

 

No comments: