Tuesday, November 5, 2013

Hamdi v. Rumsfeld case brief

Hamdi v. Rumsfeld case brief summary
542 U.S. 507 (2004)

Petitioners, a citizen-detainee and his father, petitioned for a writ of habeas corpus under 28 U.S.C.S. § 2241. The U.S. Court of Appeals for the Fourth Circuit ordered the petition dismissed, finding that the citizen-detainee's detention was legally authorized and that he was entitled to no further opportunity to challenge his enemy-combatant label. Certiorari was granted. The U.S. Supreme Court issued its decision in a plurality opinion.

The citizen-detainee was born in the United States, detained in Afghanistan during the United States' military action against the Taliban regime, and transferred to the United States. Pursuant to a government official's declaration, the Government contended that the citizen-detainee was an enemy combatant. Aside from unspecified screening processes and military interrogations, the citizen-detainee received no due process.


  • The Court determined that the Authorization for Use of Military Force (AUMF), 115 Stat. 224, authorized the detention of individuals in the citizen-detainee's circumstances and that the AUMF satisfied 18 U.S.C.S. § 4001(a)'s requirement that a detention be "pursuant to an Act of Congress." 
  • However, under the Mathews analysis, the Court determined that the citizen-detainee, seeking to challenge his classification as an enemy combatant, was entitled to receive notice of the factual basis for his classification, and a fair opportunity to rebut the Government's factual assertions before a neutral decisionmaker. 
  • The Court rejected the Government's assertion that separation of powers principles mandated a heavily circumscribed role for the courts in such circumstances.

The Supreme Court vacated the appellate court's judgment and remanded the case for further proceedings.

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