Hamdi v. Rumsfeld

Hamdi v. Rumsfeld
542 U.S. 507 (2004)

Facts: Esam Hamdi was born in Louisiana in 1980 as an American citizen. As a young child Hamdi moved to Saudi Arabia until traveling to Afghanistan in 2001 before the attacks on the United Sates on September 11, 2001. Coalition military forces captured Hamdi and he was determined to be a “military combatant” enabling him to be held in the United Sates indefinitely without further legal proceedings until the United States determines that access to counsel or further process is warranted.

Procedure: In June 2002 a petition for a Writ of Habeas Corpus under 28 U.S.C. 2241 in the Eastern District of Virginia by Hamdi’s father Esam Fouad Hamdi. The district court ruling was in favor of Hamdi but was overturned on appeal by the Circuit Court, resulting in the case reaching the United States Supreme Court.

Issue: As an American citizen, Hamdi was labeled an “Enemy Combatant” and held “without access to legal counsel or notice of any charges against him”. Did the detainment and subsequent suppression violate Hamdi’s rights as a citizen of the United States?

Pre-Existing Rules: Under the Fifth and Fourteenth Amendments of the United States Constitution, all citizens of the United States are subject to the protection provided within the Constitution. Guaranteeing due process and the rights associated with United States Citizenship.

Holding: “A citizen designated as an “enemy combatant” must receive reason for his classification and the opportunity to refute”. Separation of powers does not “mandate a circumscribed” role of the courts. The Fourth Circuit Court was wrong in their judgment allowing the physical detainment, disposal of the case and preventing opportunity for legal counsel.

Reasoning: The rights afforded to citizens of the United Sates are a cornerstone of the Constitution and necessary to prevent any one branch of the Government from obtaining majority power/control. Hamdi was a United States citizen and granted the rights provided by the Constitution. This was tempered by admitting the importance of deferring to military expertise in times of great need. However, lack of evidence suggesting Hamdi was a definite “military combatant” was partly attributed to his lack of due process in which such compelling evidence could have been presented.

Evaluation: This is a difficult case that was a split decision among the courts especially concerning justices’ who agreed with the outcome but varied greatly in their individual reasoning. This highlights the complexity of the case that aims to balance out National Security with the constitutional rights of our citizens.