{"id":11140,"date":"2015-04-17T11:33:46","date_gmt":"2015-04-17T11:33:46","guid":{"rendered":"https:#clients.elainemichele.com\/SPC2022\/?p=11140"},"modified":"2022-11-12T13:03:50","modified_gmt":"2022-11-12T18:03:50","slug":"holders_legacy_the_constitutional_implications_of_al_aulaqi_v_panetta_1140","status":"publish","type":"articles","link":"https:\/\/clients.elainemichele.com\/SPC2022\/articles\/holders_legacy_the_constitutional_implications_of_al_aulaqi_v_panetta_1140\/","title":{"rendered":"Holder\u2019s Legacy: The Constitutional Implications of Al-Aulaqi v. Panetta"},"content":{"rendered":"
Holder\u2019s Legacy: The Constitutional Implications of Al-Aulaqi v. Panetta<\/div>\n
Vani is a doctoral student in Composition and Cultural Rhetoric at Syracuse University.<\/div>\n
Vani Kannan<\/div>\n
In September 2014, after nearly six years in the position, Eric Holder resigned as Attorney General. Popular media celebrated Holder\u2019s record on civil and voting rights. However, the American Civil Liberties Union (ACLU) criticized his record on national security. In particular, the ACLU focused on his leadership in the Justice Department approval of the CIA-led extrajudicial assassinations1 of US citizens abroad who were deemed a threat to the United States.2 <\/div>\n
Anwar Al-Aulaqi (also spelled Al-Awlaki) and his son, Abdulrahman, represent two of these assassinations. Both were killed in 2011, in two separate drone strikes in Yemen.  The ACLU, along with the Center for Constitutional Rights (CCR) and Nasser al-Aulaqi (Anwar\u2019s father and Abdulrahman\u2019s grandfather), filed a suit against former CIA director and current defense secretary Leon Panetta. In April of this year, the case was dismissed by the US District Court for the District of Columbia.3<\/div>\n
Because the plaintiffs decided not to appeal the case, it has faded from public discourse in recent months. However, it is important to understand the long-ranging Constitutional implications of this court ruling, particularly in light of debates surrounding Holder\u2019s legacy as attorney general. <\/div>\n
The constitutional rights-based framework of this article risks sacrificing a more inclusive, transnational understanding of the horrific effects of drone warfare on non-US citizens in the countries most impacted by it (including, but not limited to, Yemen, Pakistan, Afghanistan, and Somalia4). Anwar and Abdulrahman Al-Aulaqi represent just two out of thousands of civilian casualties\u2014because they are US citizens, their cases were much more widely publicized in the US than others. It is crucially important to become familiar with this case, because it implies that the rights to due process of law and the right to a trial by jury are subject to reinterpretation during a time of war. But before moving on, I want to acknowledge that this case exists within a web of larger crackdowns on dissent in the post-9\/11 era.<\/div>\n
Legal analysts have argued that the question of whether the US government can legally assassinate a US citizen in another country raises questions that \u201creach to the core of constitutional rights to life and liberty.\u201d5 In Al-Aulaqi v. Panetta, the ACLU and CCR argued that the assassinations violated the Fourth Amendment prohibition on unreasonable seizures, the Fifth Amendment right to due process, the ban on singling out an individual or group for punishment without trial, and international law.6  The plaintiffs acknowledged that assassination without due process is legally allowed as a last resort to \u201cavert a concrete, specific, and imminent threat of death or physical injury,\u201d and only \u201cagainst individuals who are directly participating in hostilities against the United States.\u201d7 However, they argued that senior CIA and military leaders who authorized and directed the killings violated several standards, particularly the imperative to \u201ctake all possible steps to avoid harming civilian bystanders.\u201d8 <\/div>\n
Ultimately, Al-Aulaqi v. Panetta was dismissed on the grounds that the court could not assess whether the assassination was constitutional.9 This decision invoked the military and state secrets\u2019 privilege, which has the power to dismiss cases \u201cin exceptional circumstances\u201d in the interest of national security. This court opinion justifies the assassination of Anwar on the grounds that he was considered a terrorist leader and argues that Abdulrahman was killed accidentally by a drone strike targeting an Egyptian man named Ibraham Al-Banna.10  <\/div>\n
Anwar was killed in a \u201cpersonality strike,\u201d which indicates that the US was specifically targeting \u201can individual whose identity is known.\u201d11 A \u201csignature strike,\u201d on the other hand, describes a strike in which \u201cthe US conducts targeting without knowing of the individuals targeted. This is a controversial practice because it profiles people based on \u201cbehavior or affiliations.\u201d12 <\/div>\n
There is considerable conflict surrounding the justification for the drone strike that killed Abdulrahman. The Obama administration reserves the right to target \u201cmilitary-age\u201d Muslim men (21 years or older), and after Abdulrahman was killed, Western newspapers mistakenly reported that he was 21, not 16.13 Other reports define the assassination as \u201ccollateral,\u201d or accidental. Former White House press secretary Robert Gibbs infamously responded to questions about Abdulrahman\u2019s assassination by linking it to Anwar\u2019s affiliations: <\/div>\n
<\/div>\n
I\u2019m not going to get into Anwar al-Awlaki\u2019s son. I know that Anwar al-Awlaki renounced his citizenship . . . I would suggest that you should have a far more responsible father. If they\u2019re truly concerned about the well-being of their children, I don\u2019t think becoming an al-Qaeda jihadist terrorist is the best way to go about doing your business.14 <\/div>\n
<\/div>\n
Gibbs draws alarming links between citizenship, family, terrorism, and assassination\u2014and opens up the possibility that Abdulrahman was killed as a personality strike. In the article \u201cInside America\u2019s Dirty Wars,\u201d Jeremy Scahill lays bare these contradictions:<\/div>\n
<\/div>\n
A former senior official in the Obama administration told me that after Abdulrahman\u2019s killing, the president was \u201csurprised and upset and wanted an explanation.\u201d . . .  Once it became clear that the teenager had been killed, he added, military and intelligence officials asserted, \u201cIt was a mistake, a bad mistake.\u201d However, John Brennan, at the time President Obama\u2019s senior adviser on counterterrorism and homeland security, \u201csuspected that the kid had been killed intentionally and ordered a review. I don\u2019t know what happened with the review.\u201d15 <\/div>\n
<\/div>\n
How did Holder navigate these contradictions and justify the assassinations? By denying that there were contradictions at all. In a letter that he sent to Patrick Leahy, chairman of the Senate Judiciary Committee, Holder writes, \u201cThe decision to target Anwar al-Aulaqi was lawful, it was considered, and it was just.\u201d He repeatedly invokes the \u201claws of war,\u201d which seem to supersede constitutional rights in this assassination. Specifically, he argues that lethal force should only be used if a suspected terrorist cannot be captured. Despite the conflicting information surrounding Abdulrahman\u2019s assassination, Holder maintains that he was killed accidentally\u2014that he was, is, collateral. <\/div>\n
What does this mean\u2014the justifications, and the fact that Al-Aulaqi v. Panetta was dismissed on the grounds that the courts cannot rule on the limits of the government\u2019s claimed authority?16 Jameel Jaffer, ACLU Deputy Legal Director and Director of the ACLU Center for Democracy, expressed grave concern that the justice department has instituted \u201cvague\u201d and \u201celastic\u201d definitions of \u201cimminent threat\u201d and \u201cinfeasible\u201d capture\u2014the terms that justified Anwar\u2019s assassination.17 Jaffer holds that through the Al-Aulaqi v. Panetta decision: \u201cthe government has the authority to carry out targeted killings of US citizens without presenting evidence to a judge before the fact or after . . . Without saying so explicitly, the government claims the authority to kill American terrorism suspects in secret.\u201d<\/div>\n
As Al-Aulaqi v. Panetta demonstrates, during a time of war, constitutional protections are considerably less secure, and the rights guaranteed to citizens do not necessarily hold across geographic borders. In the post-Holder era, will we see more and more people labeled \u201cdangerous\u201d and extrajudicially assassinated? While Holder has received accolades for his support for civil rights, we have to consider who is legally enfolded under his definition of \u201ccivilian,\u201d and who\u2014by virtue of religion, skin color, citizenship status, or geographic location\u2014is not.<\/div>\n
<\/div>\n
1-17Visit www.peacecouncil.net for sources and endnotes.<\/div>\n
  <\/div>\n
<\/div>\n
(Endnotes)<\/div>\n
1 <\/span> The use of the term \u201cassassination\u201d is intentional here, reflecting concerns about the questionable legality of these deaths by drone strike. In his address to Northwestern University School of Law, Attorney General Eric Holder said the following about the term: \u201cSome have called such operations \u2018assassinations.\u2019 They are not, and the use of that loaded term is misplaced.   Assassinations are unlawful killings. Here, for the reasons I have given, the US government\u2019s use of lethal force in self defense against a leader of al Qaeda or an associated force who presents an imminent threat of violent attack would not be unlawful \u2014 and therefore would not violate the Executive Order banning assassination or criminal statutes.\u201d<\/div>\n
2 <\/span><\/div>\n
 http:\/\/www.democracynow.org\/2014\/9\/26\/eric_holders_complex_legacy_voting_rights<\/div>\n
3 <\/span><\/div>\n
 \u201cAl-Aulaqi v. Panetta.\u201d Center for Constitutional Rights, n.p., n.d. Web. 15 May 2014. <http:\/\/ccrjustice.org\/targetedkillings><\/div>\n
<\/div>\n
4 <\/span> The report Living Under Drones offers in-depth analysis of the effects of drone warfare specifically in Pakistan.<\/div>\n
5 <\/span><\/div>\n
 Epstein, Michael. \u201cThe Curious Case of Anwar Al-Aulaqi: Is Targeting a Terrorist for Execution by Drone Strike a Due Process Violation when the Terrorist is a United States Citizen?\u201d Michigan State Journal of International Law 19.3(2011): 723-744. Print. (p.744).<\/div>\n
6 <\/span><\/div>\n
 \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d American Civil Liberties Union, n.p., n.d. Web. 10 May 2014. <https:\/\/www.aclu.org\/national-security\/al-aulaqi-v-panetta> Other legal analysis argues that the Al-Aulaqi assassinations erode the Treason Clause as well.<\/div>\n
7 <\/span> \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d<\/div>\n
8 <\/span><\/div>\n
 \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d<\/div>\n
9 <\/span><\/div>\n
 \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d<\/div>\n
10 <\/span><\/div>\n
 A claim that has been contested by journalists like Jeremy Scahill (see Dirty Wars).<\/div>\n
11 <\/span> Williams, Brian Glyn. \u201cInside the Murky World of \u2018Signature Strikes\u2019 and the Killing of Americans with Drones.\u201d The Huffington Post, n.p., 31 May 2013. Web. 15 May 2014. http:\/\/www.huffingtonpost.com\/brian-glyn-williams\/nside-the-murky-world-of-_b_3367780.html<\/div>\n
<\/div>\n
12 <\/span> \u201cThe Civilian Impact of Drones: Unexamined Costs, Unanswered Questions.\u201d New York\/Washington, DC: Columbia Law School Human Rights Clinic & Center for Civilians in Conflict, 2012. Print. (p.8).<\/div>\n
13 <\/span> Finn, Tom & Noah Browning. \u201cAn American Teenager in Yemen: Paying for the Sins of His Father?\u201d Time, n.p., 27 October 2011. Web. 10 May 2014. <http:\/\/content.time.com\/time\/world\/article\/0,8599,2097899,00.html><\/div>\n
<\/div>\n
14 <\/span> \u201cRobert Gibbs Blames Al Awlaki 16 Year Old Son\u2019s Death by Drone on his Having a Terrorist Father.\u201d Just Foreign Policy, n.p., 26 October 2012. YouTube. Web. 14 April 2014.<\/div>\n
<\/div>\n
15 <\/span> Scahill, Jeremy. \u201cInside America\u2019s Dirty Wars: How Three US Citizens Were Killed by Their Own Government in the Space of One Month in 2011.\u201d The Nation. 13 May 2013. Print. 13-20. (p.20).<\/div>\n
<\/div>\n
16 <\/span> Jaffer, Jameel. \u201cThe Justice Department\u2019s White Paper on Targeted Killing.\u201d American Civil Liberties Union, n.p., 04 February 2013. Web. 10 May 2014. <https:\/\/www.aclu.org\/blog\/national-security\/justice-departments-white-paper-targeted-killing><\/div>\n
17 <\/span><\/div>\n
 His concerns come from a Department of Justice white paper made available to the public, available here (http:\/\/www.lawfareblog.com\/wp-content\/uploads\/2013\/02\/020413_DOJ_White_Paper.pdf), which offers further analysis of the Al-Aulaqi assassinations.<\/div>\n
<\/p>\n
Anwar Al-Aulaqi at Dar al Hijrah Mosque on Oct. 4 2001, in Falls Church, VA.<\/div>\n
Tracy Woodward\/The Washington Post\/Getty Images<\/div>\n<\/div>\n

In September 2014, after nearly six years in the position, Eric Holder resigned as Attorney General. Popular media celebrated Holder\u2019s record on civil and voting rights. However, the American Civil Liberties Union (ACLU) criticized his record on national security. In particular, the ACLU focused on his leadership in the Justice Department approval of the CIA-led extrajudicial assassinations [1]<\/font> of US citizens abroad who were deemed a threat to the United States. [2]<\/p>\n

Anwar Al-Aulaqi (also spelled Al-Awlaki) and his son, Abdulrahman, represent two of these assassinations. Both were killed in 2011, in two separate drone strikes in Yemen.  The ACLU, along with the Center for Constitutional Rights (CCR) and Nasser al-Aulaqi (Anwar\u2019s father and Abdulrahman\u2019s grandfather), filed a suit against former CIA director and current defense secretary Leon Panetta. In April of this year, the case was dismissed by the US District Court for the District of Columbia. [3]<\/p>\n

Because the plaintiffs decided not to appeal the case, it has faded from public discourse in recent months. However, it is important to understand the long-ranging Constitutional implications of this court ruling, particularly in light of debates surrounding Holder\u2019s legacy as attorney general. <\/p>\n

The constitutional rights-based framework of this article risks sacrificing a more inclusive, transnational understanding of the horrific effects of drone warfare on non-US citizens in the countries most impacted by it (including, but not limited to, Yemen, Pakistan, Afghanistan, and Somalia [4]). Anwar and Abdulrahman Al-Aulaqi represent just two out of thousands of civilian casualties\u2014because they are US citizens, their cases were much more widely publicized in the US than others. It is crucially important to become familiar with this case, because it implies that the rights to due process of law and the right to a trial by jury are subject to reinterpretation during a time of war. But before moving on, I want to acknowledge that this case exists within a web of larger crackdowns on dissent in the post-9\/11 era.<\/p>\n

Legal analysts have argued that the question of whether the US government can legally assassinate a US citizen in another country raises questions that \u201creach to the core of constitutional rights to life and liberty.\u201d [5] In Al-Aulaqi v. Panetta, the ACLU and CCR argued that the assassinations violated the Fourth Amendment prohibition on unreasonable seizures, the Fifth Amendment right to due process, the ban on singling out an individual or group for punishment without trial, and international law. [6]  The plaintiffs acknowledged that assassination without due process is legally allowed as a last resort to \u201cavert a concrete, specific, and imminent threat of death or physical injury,\u201d and only \u201cagainst individuals who are directly participating in hostilities against the United States.\u201d [7] However, they argued that senior CIA and military leaders who authorized and directed the killings violated several standards, particularly the imperative to \u201ctake all possible steps to avoid harming civilian bystanders.\u201d [8]<\/p>\n

Ultimately, Al-Aulaqi v. Panetta was dismissed on the grounds that the court could not assess whether the assassination was constitutional. [9] This decision invoked the military and state secrets\u2019 privilege, which has the power to dismiss cases \u201cin exceptional circumstances\u201d in the interest of national security. This court opinion justifies the assassination of Anwar on the grounds that he was considered a terrorist leader and argues that Abdulrahman was killed accidentally by a drone strike targeting an Egyptian man named Ibraham Al-Banna. [10]<\/p>\n

Anwar was killed in a \u201cpersonality strike,\u201d which indicates that the US was specifically targeting \u201can individual whose identity is known.\u201d [11] A \u201csignature strike,\u201d on the other hand, describes a strike in which \u201cthe US conducts targeting without knowing of the individuals targeted. This is a controversial practice because it profiles people based on \u201cbehavior or affiliations.\u201d [12]<\/p>\n

There is considerable conflict surrounding the justification for the drone strike that killed Abdulrahman. The Obama administration reserves the right to target \u201cmilitary-age\u201d Muslim men (21 years or older), and after Abdulrahman was killed, Western newspapers mistakenly reported that he was 21, not 16. [13] Other reports define the assassination as \u201ccollateral,\u201d or accidental. Former White House press secretary Robert Gibbs infamously responded to questions about Abdulrahman\u2019s assassination by linking it to Anwar\u2019s affiliations: <\/p>\n

I\u2019m not going to get into Anwar al-Awlaki\u2019s son. I know that Anwar al-Awlaki renounced his citizenship . . . I would suggest that you should have a far more responsible father. If they\u2019re truly concerned about the well-being of their children, I don\u2019t think becoming an al-Qaeda jihadist terrorist is the best way to go about doing your business. [14]<\/p>\n

Gibbs draws alarming links between citizenship, family, terrorism, and assassination\u2014and opens up the possibility that Abdulrahman was killed as a personality strike. In the article \u201cInside America\u2019s Dirty Wars,\u201d Jeremy Scahill lays bare these contradictions:<\/p>\n

 <\/p>\n

A former senior official in the Obama administration told me that after Abdulrahman\u2019s killing, the president was \u201csurprised and upset and wanted an explanation.\u201d . . .  Once it became clear that the teenager had been killed, he added, military and intelligence officials asserted, \u201cIt was a mistake, a bad mistake.\u201d However, John Brennan, at the time President Obama\u2019s senior adviser on counterterrorism and homeland security, \u201csuspected that the kid had been killed intentionally and ordered a review. I don\u2019t know what happened with the review.\u201d[15]<\/p>\n

 <\/p>\n

How did Holder navigate these contradictions and justify the assassinations? By denying that there were contradictions at all. In a letter that he sent to Patrick Leahy, chairman of the Senate Judiciary Committee, Holder writes, \u201cThe decision to target Anwar al-Aulaqi was lawful, it was considered, and it was just.\u201d He repeatedly invokes the \u201claws of war,\u201d which seem to supersede constitutional rights in this assassination. Specifically, he argues that lethal force should only be used if a suspected terrorist cannot be captured. Despite the conflicting information surrounding Abdulrahman\u2019s assassination, Holder maintains that he was killed accidentally\u2014that he was, is, collateral. <\/p>\n

What does this mean\u2014the justifications, and the fact that Al-Aulaqi v. Panetta was dismissed on the grounds that the courts cannot rule on the limits of the government\u2019s claimed authority?[16] Jameel Jaffer, ACLU Deputy Legal Director and Director of the ACLU Center for Democracy, expressed grave concern that the justice department has instituted \u201cvague\u201d and \u201celastic\u201d definitions of \u201cimminent threat\u201d and \u201cinfeasible\u201d capture\u2014the terms that justified Anwar\u2019s assassination.[17] Jaffer holds that through the Al-Aulaqi v. Panetta decision: \u201cthe government has the authority to carry out targeted killings of US citizens without presenting evidence to a judge before the fact or after . . . Without saying so explicitly, the government claims the authority to kill American terrorism suspects in secret.\u201d<\/p>\n

As Al-Aulaqi v. Panetta demonstrates, during a time of war, constitutional protections are considerably less secure, and the rights guaranteed to citizens do not necessarily hold across geographic borders. In the post-Holder era, will we see more and more people labeled \u201cdangerous\u201d and extrajudicially assassinated? While Holder has received accolades for his support for civil rights, we have to consider who is legally enfolded under his definition of \u201ccivilian,\u201d and who\u2014by virtue of religion, skin color, citizenship status, or geographic location\u2014is not.<\/p>\n

 <\/p>\n

Endnotes<\/b><\/span><\/p>\n

1  The use of the term \u201cassassination\u201d is intentional here, reflecting concerns about the questionable legality of these deaths by drone strike. In his address to Northwestern University School of Law, Attorney General Eric Holder said the following about the term: \u201cSome have called such operations \u2018assassinations.\u2019 They are not, and the use of that loaded term is misplaced.   Assassinations are unlawful killings. Here, for the reasons I have given, the US government\u2019s use of lethal force in self defense against a leader of al Qaeda or an associated force who presents an imminent threat of violent attack would not be unlawful \u2014 and therefore would not violate the Executive Order banning assassination or criminal statutes.\u201d<\/o:p><\/span><\/p>\n

2  http:\/\/www.democracynow.org\/2014\/9\/26\/eric_holders_complex_legacy_voting_rights<\/a><\/o:p><\/span><\/p>\n

3  \u201cAl-Aulaqi v. Panetta.\u201d Center for Constitutional Rights, n.p., n.d. Web. 15 May 2014. <http:\/\/ccrjustice.org\/targetedkillings<\/a>><\/o:p><\/span><\/p>\n

4  The report Living Under Drones offers in-depth analysis of the effects of drone warfare specifically in Pakistan<\/st1:place><\/st1:country-region>.<\/o:p><\/span><\/p>\n

5  Epstein, Michael. \u201cThe Curious Case of Anwar Al-Aulaqi: Is Targeting a Terrorist for Execution by Drone Strike a Due Process Violation when the Terrorist is a United States Citizen?\u201d Michigan<\/st1:placename> State<\/st1:placetype><\/st1:place> Journal of International Law 19.3(2011): 723-744. Print. (p.744).<\/o:p><\/span><\/p>\n

6  \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d American Civil Liberties Union<\/st1:place>, n.p., n.d. Web. 10 May 2014. <https:\/\/www.aclu.org\/national-security\/al-aulaqi-v-panetta<\/a>> Other legal analysis argues that the Al-Aulaqi assassinations erode the Treason Clause as well.<\/o:p><\/span><\/p>\n

7  \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d<\/o:p><\/span><\/p>\n

8  \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d<\/o:p><\/span><\/p>\n

9  \u201cAl-Aulaqi v. Panetta: Lawsuit Challenging Targeted Killings.\u201d<\/o:p><\/span><\/p>\n

10  A claim that has been contested by journalists like Jeremy Scahill (see Dirty Wars).<\/o:p><\/span><\/p>\n

11  Williams, Brian Glyn. \u201cInside the Murky World of \u2018Signature Strikes\u2019 and the Killing of Americans with Drones.\u201d The Huffington Post, n.p., 31 May 2013. Web. 15 May 2014. http:\/\/www.huffingtonpost.com\/brian-glyn-williams\/nside-the-murky-world-of-_b_3367780.html<\/a><\/o:p><\/span><\/p>\n

12  \u201cThe Civilian Impact of Drones: Unexamined Costs, Unanswered Questions.\u201d New York\/Washington, DC: Columbia<\/st1:placename> Law<\/st1:placename> School<\/st1:placetype><\/st1:place> Human Rights Clinic & Center for Civilians in Conflict, 2012. Print. (p.8).<\/o:p><\/span><\/p>\n

13  Finn, Tom & Noah Browning. \u201cAn American Teenager in Yemen<\/st1:place><\/st1:country-region>: Paying for the Sins of His Father?\u201d Time, n.p., 27 October 2011. Web. 10 May 2014. <http:\/\/content.time.com\/time\/world\/article\/0,8599,2097899,00.html<\/a>><\/o:p><\/span><\/p>\n

14  \u201cRobert Gibbs Blames Al Awlaki 16 Year Old Son\u2019s Death by Drone on his Having a Terrorist Father.\u201d Just Foreign Policy, n.p., 26 October 2012. YouTube. Web. 14 April 2014.<\/o:p><\/span><\/p>\n

15  Scahill, Jeremy. \u201cInside America<\/st1:place><\/st1:country-region>\u2019s Dirty Wars: How Three US Citizens Were Killed by Their Own Government in the Space of One Month in 2011.\u201d The Nation. 13 May 2013. Print. 13-20. (p.20).<\/o:p><\/span><\/p>\n

16  Jaffer, Jameel. \u201cThe Justice Department\u2019s White Paper on Targeted Killing.\u201d American Civil Liberties Union<\/st1:place>, n.p., 04 February 2013. Web. 10 May 2014. <https:\/\/www.aclu.org\/blog\/national-security\/justice-departments-white-paper-targeted-killing<\/a>><\/o:p><\/span><\/p>\n

 <\/p>\n

17  His concerns come from a Department of Justice white paper made available to the public, available here (http:\/\/www.lawfareblog.com\/wp-content\/uploads\/2013\/02\/020413_DOJ_White_Paper.pdf<\/a>), which offers further analysis of the Al-Aulaqi assassinations.<\/o:p><\/span><\/p>\n","protected":false},"excerpt":{"rendered":"

Holder\u2019s Legacy: The Constitutional Implications of Al-Aulaqi v. Panetta Vani is a doctoral student in Composition and Cultural Rhetoric at Syracuse University. Vani Kannan In September 2014, after nearly six years in the position, Eric Holder resigned as Attorney General. Popular media celebrated Holder\u2019s record on civil and voting rights….<\/p>\n

Learn More<\/span><\/i><\/a> <\/p>\n","protected":false},"featured_media":0,"parent":0,"menu_order":0,"template":"","class_list":["post-11140","articles","type-articles","status-publish","hentry"],"acf":[],"_links":{"self":[{"href":"https:\/\/clients.elainemichele.com\/SPC2022\/wp-json\/wp\/v2\/articles\/11140","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/clients.elainemichele.com\/SPC2022\/wp-json\/wp\/v2\/articles"}],"about":[{"href":"https:\/\/clients.elainemichele.com\/SPC2022\/wp-json\/wp\/v2\/types\/articles"}],"wp:attachment":[{"href":"https:\/\/clients.elainemichele.com\/SPC2022\/wp-json\/wp\/v2\/media?parent=11140"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}