Khalifh v. Bush

CourtDistrict Court, District of Columbia
DecidedJune 14, 2010
DocketCivil Action No. 2005-1189
StatusPublished

This text of Khalifh v. Bush (Khalifh v. Bush) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Khalifh v. Bush, (D.D.C. 2010).

Opinion

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FILELJ v';. ,'" rt1~ COURT,,~ECURp'YOFFICER CSO:VJ-..m ..,.­ DATE: ~!\J UN~TED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

OMAR MOHAMMED KHALIFH

Petitioner, , Civil Action No. 05-CV-1189 v.

BARACK H. OBAMA, et al.,

Respondents.

MEMORANDUM ORDER

Omar Mohammed Khalifh (ISN 695), a Libyan national,

alleges that he is illegally detained at Guantanamo Bay

Naval Base and petitions this court for a writ of habeas

corpus to secure his release. Petitioner has filed a

traverse and an amended traverse, and the government has

moved for jUdgment on the record. For the reasons that

follow{ the government's motion will be granted{ and the 1 petition for a writ of habeas corpus will be denied.

Background

Khalifh lost his right leg below the knee in 1998 or

1999 and received a prosthetic limb in mid-2001 from the

International Committee for the Red Cross Kabul Orthopaedic

Centre. J.E. 13. He was captured by Pakistani forces in

I Petitioner's counsel Cary Silverman and Edmund Burke have represented their client zealously and well, providing indepsensible service not only to their client, but also to the court. pro bono publico. in the highest tradition of the bar. Mr. Burke, in particular, traveled all the way from his home in Hawaii to GTMO and back many times. My thanks to both of them.

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Jalalabad, Pakistan, in March 2002 and subsequently

transferred to u.s. custody. He filed this petition in

2005, but his case, like all other habeas corpus petitions

from Guantanamo Bay, was put on hold until the Supreme

Court decided that Guantanamo detainees have a right to

habeas proceedings and that this court has jurisdiction to

hear them. Boumediene v. Bush, 128 S.Ct. 2229 (2008).

With Judge Hogan's omnibus Case Management Order as a

guide, I held a merits hearing on April 19 and 20, 2010.

Although he was given the option to do so, Khalifh did not

testify or listen to the proceedings remotely. I announced

my decision from the bench following the hearing, and now

issue this opinion to make a full record of my reasoning.

I. Legal Standards

The government's authority to detain Khalifh, if any,

derives from the Authorization for use of Military Force

("AUMFU), Pub. L. 107-04, 115 Stat. 224 (2001). The court

of appeals has held that the President's authority pursuant

to the AUMF at least includes, but is not necessarily

limited to, detention of "those who are part of forces

associated with Al Qaeda or the Taliban or those who

purposefully and materially support such forces in

hostilities against U.S. Coalition partners. u AI-Bihani v.

Obama, 590 F.3d 866, 872 (D.C. Cir. 2010). The government

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contends that Khalifh was a part of al-Qaida, the Taliban,

and associated forces, justifying his detention. The

government had the burden of proving the lawfulness of the

detention by a preponderance of the evidence. In re

Guantanamo Bay Detainee Litig., Misc. No. 08-442, CMO § II

(A); Awad, 646 F. Supp. 2d at 23-24; see also Al-Bihani,

590 F.3d at 878 (upholding the constitutionality of the

preponderance standard) .

A. "'Part of"

The test now applied by most jUdges of this court for

determining who is or was ~part of" al-Qaida was first

articulated by Judge Bates: "whether the individual

functions or participates within or under the command

structure of the organization - i.e., whether he receives

and executes orders or directions." Hamlily v. Obama, 616

F. Supp. 2d 63, 75 (D.D.C. 2009); see also Awad v. Obama,

646 F. Supp. 2d 20, 23 (D.D.C. 2009) (appeal pending). A

detainee may fit within or under al-Qaida's ~command

structure" even if he never actually fights for al-Qaida.

AI-Sihani, 590 F.3d at 872. Detention is lawful under the

~part of" prong if the detainee has received and executed

al-Qaida's orders, even if he has only been a cook in an

al-Qaida camp. Id.; accord Gherebi v. Obama, 609 F. Bupp.

2d 43, 69, n. 19 (D.D.C. 2009).'

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B. Temporal Issue

Khalifh does not concede that he was ever a member of

al-Qaida, the Taliban, or associated forces, see J.E. 13;

but he argues in the alternative that even if I find that

he was once a member of a detainable organization, his

membership had lapsed by the time of his capture. The

government must show that detention was lawful at the time

of capture. See Salahi v. Obama, 2010 U.S. Dist. LEXIS

'35360, at *8-9 (D.D.C. Apr. 9, 2010) (appeal pending);

Gherebi, 609 F. Supp. 2d. at 71. The government need not

show an affirmative act after 9/11, but to justify

detention it must show that the petitioner was a part of

al-Qaida, the Taliban, or related forces at the time of his

capture. See Salahi, 2010 U.S. Dist. LEXIS 35360, at *9­

10. A petitioner who may once have been part of al-Qaida

or the Taliban can show that he was no longer part of such

an entity at the time of capture by showing that he took

affirmative actions to abandon his membership. See, e.g.,

Al Ginco v. ·Obama, 626 F. Supp. 2d 123, 128-30 (D.D.C.

2009); Hatim v. Obama, 2009 WL 5191429, at *10, 12 (D.D.C.

Dec. 15, 2009). In Salahi, I held that a petitioner could

also show lapse of membership even without an affirmative

act of severance, if the evidence that the membership had

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lapsed is "credible and significant." Salahi, U.S. Dist.

LEXIS 35360, at *10-11. That proposition, however (from

which an appeal is pending) rests on unusual facts: in

Salahi's case there was a gap of nearly a decade between

his activity in al-Qaida and his subsequent capture. Id.

at *15-35.

C. Hearsay

Hearsay, along with other evidence normally excluded

by the Federal Rules of Evidence, is admissible in these

proceedings. See AI-Bihani, 590 F.3d at 879-81. All

proffered evidence has been admitted and given the weight

it deserves. See Awad, 646 F. Supp. 2d at 23.

D. Coerced Statements

Khalifh alleges that he was mistreated during

detention between "late 2004" and "early 2005," see J.E. 13

addendum, so he argues that the court should disregard his

statements during interrogation from that period.

Specifically, Khalifh alleges that during that period he

suffered painful glaucoma that was not sufficiently

treated, was kept in an extremely cold' cell that caused

pain in the metal

and was denied use of his pros·thetic leg. The government

denies mistreating Khalifh. Proof of mistreatment can

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taint a petitioner's statements, raising questions about

their reliability.

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Related

Boumediene v. Bush
553 U.S. 723 (Supreme Court, 2008)
Al Ginco v. Obama
626 F. Supp. 2d 123 (District of Columbia, 2009)
Mohammed v. Obama
704 F. Supp. 2d 1 (District of Columbia, 2009)
Hatim v. Obama
677 F. Supp. 2d 1 (District of Columbia, 2009)
Awad v. Obama
646 F. Supp. 2d 20 (District of Columbia, 2009)
Hamlily v. Obama
616 F. Supp. 2d 63 (District of Columbia, 2009)
Salahi v. Obama
710 F. Supp. 2d 1 (District of Columbia, 2010)
United States v. Karake
443 F. Supp. 2d 8 (District of Columbia, 2006)

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