CLE: 2007: Center for Terrorism Law Issues for Discussion

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CLE: 2007: Center for Terrorism Law Issues for Discussion


Jeffrey F. Addicott


St. Mary's University School of Law San Antonio Texas Alumni Homecoming, St. Mary's University School of Law Alumni Homecoming




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Terrorisn1 Law
Jeff Addicott,

Professor of Law and
Director of the Center for Terrorism Law

Print Version II School of Law at St. Mary's University

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School of Law at St. Mary's University

Jeffrey F. Addicott
ph: (2 10) 431-2274
Associate Dean for Administration
Director, Center for Terrorism Law
(www. stmarytx/ctl)
Professor of Law
B.A., 1976, University of Maryland (with honors)
J.D. , 1979, University of Alabama School of Law
LL.M., 1987, The Judge Advocate General's School
LL.M., 1992; S.J.D., 1994, University ofVirginia
School of Law
Professor Jeffrey F. Addicott is the Associate Dean for
Administration and the Director of the Center for Terrorism Law at St. Mary's
University School of Law, San Antonio, Texas. He teaches a variety of courses to
include Federal Civil Procedure, Criminal Law, Terrorism Law, Medical Malpractice
Law, Administrative Law, Civil and Common Law, and Constitutional Criminal
Procedure. An active duty Army officer in the Judge Advocate General's Corps for
twenty years (he retired in 2000 at the rank of Lieutenant Colonel), Professor
Addicott spent a quarter of his career as a senior legal advisor to the United States
Army's Special Forces. An internationally recognized authority on national security
law, terrorism law and human ri ghts law, Professor Addicott not only lectures and
participates in professional and academic organizations both in the United States and
abroad, but he is also a frequent contributor to national and international news shows
to include FOX News Channel and MSNBC. Professor Addicott is a prolific author,
publishing over 20 books, articles, and monographs on a variety of legal topics.
Addicott's most recent book (2007) is entitled: Terrorism Law: Cases, Materials,
Among his many contributions to the field, Professor Addicott pioneered the teaching
of law of war and human rights courses to the militaries of numerous nascent
democracies in Eastern Europe and Latin America. For these efforts he was awarded
the Legion ofMerit, named the 1993 Army Judge Advocate ofthe year, and honored
as a co-recipient of the American Bar Association's Hodson award. He has served in
senior legal positions in Germany, Korea, Panama, and throughout the United States.
Professor Addicott holds a Doctor of Juridical Science (S.J.D.) and Master of Laws
(LL.M.) from the University of Virginia School of Law. He also received a Master of
Laws (LL.M.) from the Army Judge Advocate General 's School and a Juris Doctor
(J.D.) from the University of Alabama School of Law.

• Doctor of Juridical Science (S.J.D.), University of Virginia School of Law
Graduate Program, Charlottesville, Virginia (1994).
• Master of Laws (LL.M.), University ofVirgi nia School ofLaw Graduate
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Program, Charlottesville, Virginia (1992).
Master of Laws (LL.M.), The Judge Advocate General's School,
Charlottesville, Virginia (1987).
Command and General Staff College, Combined Arms and Services Staff
School, Fort Leavenworth, Kansas (1985).
Juris Doctor (J.D.), University of Alabama School of Law, Tuscaloosa,
Alabama (1979).
Bachelor of Arts (B.A.) (with Honors), University of Maryland, College Park,
Maryland (1976).

Jeffrey Addicott is a Professor of Law at St. Mary's University School of Law, San
Antonio, Texas, where he teaches Civil Procedure, Medical Malpractice,
Comparative Law, Administrative Law, Criminal Law, Constitutional Criminal Law,
National Security Law, and Terrorism Law. He has taught both as an adjunct
professor and as a full professor at the following institutions:
• 1980-1981: Adjunct Professor, University of Maryland; Berlin, Germany.
Business Law and Government.
• 1982-1983: Adjunct Professor, Central Texas College; Korea. Business Law.
• 1984-1985: Professor, Academy of Health Sciences; San Antonio, TX. Health
• 1988-1989: Adjunct Professor, Chapman College; Tacoma, W A. Graduate
level International Law.
• 1989-1992: Assistant Chair, International Law Department, The Judge
Advocate General's School; Charlottesville, VA. Graduate level Intemational
Law, National Security law and Criminal Law.
• 1995: Adjunct Professor, Central Michigan University: Washington, D.C.
Graduate level International Law.
• 1996: Adjunct Professor, Central Texas College; Central Michigan University;
Webster University; Fayetteville, NC. Criminal Law, Graduate level Business
Law, Graduate level Administrative Law.
• 1997: Adjunct Professor, Campbell University; Fayetteville, NC. Business
• 1998-2001: Adjunct Professor, Central Michigan University. Savannah, GA;
Fort Myers, FL; Fayetteville, NC; Arlington, LA. Graduate level International
Law and Administrative Law.
• Cases and Materials on Te1Torism Law, 3rd ed. (Tucson, AZ: Lawyers and
Judges Pub. Co., 2006).
• Human Rights & International Humanitarian Law Handbook (Bogota,
Colombia: Imprenta y Publicaciones de las Fuerzas Militares, 1999).
• Encyclopedia of American Civil Liberties, 3 vols. , Paul Finkelman, editor,
(New York: Routledge, 2006).
• The Global War on Terrorism: Assessing the American Response, John Davis,
editor, (Hauppauge, NY: Nova Science Publishers, Inc., 2004).


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• Transnational Threats: Blending Law Enforcement and Military Strategies,
Carolyn W. Pumphrey, editor, (Carlisle, PA: Strategic Studies Institute, 2000).
• Dr. Mudd and the Lincoln Assassination: The Case Reopened, John Paul Jones,
editor, (Conshohocken, PA: Combined Books, 1995).

• Contractors on the "Battlefield": Providing Adequate Protection, AntiTerrorism Training, and Personnel Recovery for Civilian Contractors
Accompanying the Military in Combat and Contingency Operations, 28
Houston Journal oflnternational Law 323 (2006)
• The Practice ofRendition in the War on Terror, 6 The Long Term View 77
(Spring 2006).
• St. Mary's Center for Terrorism Law, San Antonio Lawyer, July-August 2006,
at 12.
• Cyberterrorism: Partnership Between the Private Sector and the Government,
The 9th World Multiconference on Systemics, Cybernetics and Informatics,
July 2005, at 375.
• In Defense of U.S Counterterror Policies, 9 Peace & Policy 21 (2004).
• Book Review: Law and Bioterrorism, 28 Melbourne University Law Review
253 (2004).
• Into the Star Chamber: Does the United States Engage in the Use ofTorture or
Similar Illegal Practices in the War on Terror?, 92 Kentucky Law Journal 849
(2003- 2004).
• Proposal for a New Executive Order on Assassination, 3 7 University of
Richmond Law Review 751 (2003).
• Storm Clouds on the Horizon ofDarwinism: Teaching the Anthropic Principle
and Intelligent Design in the Public Schools, 63 Ohio State Law Journal
Review 1508 (2002).
• Legal and Policy Implications for a New Era: The War on Terror, 4 The
Scholar: St. Mary's Law Review on Minority Issues 209 (2002).
• Building Democracies with Southern Command's Legal Engagement Strategy,
31 Parameters 72 (2001) (with Guy B. Roberts).
• Promoting Human Rights Values in Cuba 's Post-Castro Military, 3 Journal of
National Security Law 11 (1999) (with Manuel Supervielle).
• Las Fuerzas Especiales y la Promocion de los Derechos Humanos, Dialogo,
Apr-June 1997, at 13.
• Human Rights and Special Forces, Special Warfare, Dec. 1996, at 30.
• A Special Forces Human Rights Policy, The Army Lawyer, Sept. 1996, at 47.
• Legal Training Handbookfor the Ukrainian Military, The Army Lawyer, July
1995, at 60.
• Institutionalizing Human Rights Values in the Militaries of the New
Democracies: The Case ofPeru (Doctoral Thesis, Charlottesville, VA 1994).
• Recent Army JAG Corps Initiatives to Enhance Human Rights Training at the
School of the Americas, The Army Lawyer, Dec. 1994, at 45.
• Policy Guidance for the Transfer of DoD Installations to the Government of
Panama, The Army Lawyer, Oct. 1994, at 68.
• Promoting the Rule ofLaw and Human Rights, Military Review, Aug. 1994, at
38, (with Andrew M. Warner), reprinted in part as Nuevas Misiones para los
Auditores Militares: Promoviendo el Imperio de la Ley en las Fuerzas
Armadas de Democracias Emergentes e Inestables, Military Review Edicion
Hispanoamericana, May-June 1994, at 2.
• 25th Anniversary ofMy Lai: Time to Inculcate the Lessons, 139 Military Law
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Review 153 (1993) (with William A. Hudson, Jr.).
Military Medical Witness in Litigation, Military Medicine, Apr. 1993, at 126.
New Missions for JAGs: Promoting the Rule ofLaw in Militaries ofEmerging
Democracies, American Bar Association National Security Law Report, Mar.
1993, at 1 (with Andrew M. Warner)
JAG Corps Poised for New Defense Missions: Human Rights Training in Peru,
The Army Lawyer, Feb. 1993, at 78 (with Andrew M. Warner).
Lecons du Passe- My Lai, 31 Revue de Droit Militaire et de Droit de laGuerre
73 (1992), reprinted in part at 13 9 Military Law Review 153.
Operation Desert Storm, R. E. Lee or W. T. Sherman?, 136 Military Law
Review 115 (1992) reprinted in Command Magazine, July-Aug. 1992, at 38;
Codification ofthe Special Forces Exception, The Army Lawyer, May 1992, at
The Status of the Diplomatic Bag: A Proposed American Position, 13 Houston
Journal oflnternational Law 221 (1991).
The United States ofAmerica: Champion of the Rule ofLaw or the New World
Order?, 6 Florida Journal oflnternational Law 63 (1990).
Proceedings ofthe First Center for Law and Military Operations Symposium,
18-20 April 1990, The Army Lawyer, Dec. 1990, at 47.
Developing a Security Strategy for Indochina, 128 Military Law Review 35

• Forthcoming 2006: Addicott, The Abu Ghraib Story, IDF Law Review.
• Forthcoming 2006: Addicott, My Lai Massacre, in War Crimes: An Historical
Encyclopedia, Larry Hufford and Elizabeth Pugliese, Editors (ABC-CLIO,
Publishers, Inc., 2006).
• Forthcoming 2007: Addicott, Peru and Human Rights Law, in Fear of
Persecution: Global Human Rights, International Law, and Human WellBeing, James White, Editor (to be determined).

Other publications include more than 50 magazine ruiicles, op-ed pieces, and
continuing legal education monographs to include:
• Profile: The Centerfor Terrorism Law, Safeguard Review, Aug./Sept. 2005 , at
• Derechos Humanos: Decalogo de las Fuerzas del Orden, (Lima, Peru:
Comando Conjunto de las Fuerzas Armadas, 1993).
• Code ofConduct.for Participants in Military Operations, (Kiev, Ukraine,
Ministry of Defense: Lubava, 199 5).

• Foreign presentations include numerous professional lectures at universities
and government institutions in Colombia, Peru, Ukraine, Gem1any, Austria,
Canada, Thailand, Japan, Honduras, Haiti, Egypt, Panruna, Guatemala,
Albania, Okinawa, South Korea, England, Mexico, Sweden, Ireland, Greece
and Uruguay.
• Presentations in the United States include nw11erous appearances at universities,r/print.php?go=fac_addicott&id=&print=1


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and local, State, and federal institutions as well as more than 400 appearances
on radio and television broadcasts to include FOX News Channel, MSNBC
and CNN.

• Co-recipient: American Bar Association' s "Hodson Award for 1995," awarded
each year to the "outstanding public sector law office in the nation."
• Recipient: "1993 Outstanding Career Army Judge Advocate Award," awarded
by the Judge Advocates Bar Association.
• Recipient: "1983 Academy of Health Sciences Commander's A ward Hospital Law."
• Member of the Bar of Alabama
• U.S. Supreme Court
• Court of Military Appeals
• International Society for Military Law & the Law of War
• Military Order of the World Wars
• Phi Kappa Phi Honor Society
• American Bar Association, Special Forces Association
• board member of the Toda Institute for Peace
• contributing editor for JURIST
• Director, Center for Terrorism Law

Jeffrey Addicott was born in Pensacola, Florida.



School of Law at St. Mary's University
School of Law, St. Mary's University, One Camino Santa Maria, San Antonio, Texas

1_......._ __ • If_ .. _

Center for Terrorism Law
Issues for Discussion
30 March 27, 2007
Professor Jeff Addicott


Defining Terrorism

The Secretary General of the United Nations, Kofi Annan, offered th is 2005
[A]ny action constitutes terrorism if it is intended to cause death or serious bodily harm to
civilians or non-combatants, with the pwpose of intimidating a population or compelling
a Government or an international organization to do or abstain from doing any act

II. What is the Global War on Terrorism?

A. Executive Perspective
Article II, the Commander in Chief

B. Supreme Court Perspective
Hamdi v. Rumsfeld 2004
Ham.dan v. Rumsfeld 2006

C. Congressional Perspective

Prompted by the Supreme Court's holding in Hamdan v. Rumsfeld, an energized
Congress understood that they could no longer remain on the sidelines in the War on
Terror. In late 2006, Congress established the creation of military commissions,
affirming quite satisfactorily that the Military Commission Act of 2006 (MCA) was
consistent with the requirements of Common Article 3 of the Geneva Conventions - the
military commissions so established constitute a "regularly constituted court," affording
all the necessary "judicial guarantees which are recognized as indispensable by civilized
peoples." Indeed, with the passage of the MCA, Congress has firmly committed itself to
the view that the nation is at war and that the legislative branch of government has a
significant role to play in a variety of legal issues associated with the "enemy
combatants" - both legal and illegal - that seek to do great physical harm to the United
States and its allies. While the Detainee Treatment Act of 2005 provided an advanced
signal that Congress was at last willing to get involved in a limited manner in some of the
thorny legal aspects of the War on Terror, the MCA represents a major Congressional
shift in scope.
In short, the MCA is a resounding statutory broadside that impacts
forcefully and with great effect across the entire legal landscape.
Above all, the MCA has certainly washed away all doubt regarding Congress'
willingness to characterize the War on Terror as a real global war against real enemies
who desire to murder and terrori ze. Accordingly, Congress has demonstrated that it is
more than willing to employ the full weight of the rule of Jaw pertaining to armed conflict
against our enemies.
Not only does the MCA provide crystal clear guidance in the context of the
establishment and operation of military commissions to try "any alien unlawful enemy
combatant" (al -Qa'eda and al-Qa'eda-styled Islamic terTorists) it provides concrete
statutory definitions concerning a wide variety of terms that have been previously hotly
debated. The MCA al so clearly places a large legal "seal of approval" on many of the
initiati ves taken by the Bush Administration in the War on Terror. For instance, the
MCA defines "unlawful enemy combatants" in precise language while recognizing in the
same breath the lawful functioning of the Combatant Status Review Tribunal for enemy
combatant determination set up by the Dep artmen t of Defense in response to the 2004
Hamdi v. Rumsfeld ruling. The MCA reads:
(i) a person who has engaged in hostilities or who has purposefully and materially supported
hostilities against the United States or its co-bell igerents who is not a lawful enemy
combatant (including a person who is part of the Tali ban, a! Qaeda, or associated forces); or
(ii) a person who, before, on, or after the date of the enactment of the Military Commissions
Act of 2006, has been determ ined to be an unlawful enemy combatant by a Combatant Status
Review Tribunal or another competent tribunal established under the authority of the
President or the Secretary of Defense.

The MCA also lists in detail the cri minal offenses that fall within the jurisdiction of the
military commission.
Apart from the traditional list of war crimes the MCA
appropriately includes "conspiracy" and "providing material support for terrorism,"
drawing definitional language from the Material Support provisions at Section 2339A for
the later offense. In addition, reaffirming the fact that the United States is in a state of
hostilities, the MCA addresses the matter of streamlining the process for dealing with the
large number of petitions filed by lawyers on behalf enemy combatants in the federal
court system. Again, if one recognizes the government's premise that the nation is at war
and the laws of war apply, then the MCA properly deals with restricting habeas corpus
and providing for other limitations on the jurisdiction of civilian courts.
In the sphere of authorizing trial by military commission, the Congress wisely allows
for the military commission to operate in the traditional manner of all previous military
commissions (hundreds were tried by military commissions in World War II, some were
even U.S. citizens) and consider, for example, hearsay evidence and information gathered
without a search warrant. The MCA holds that "[e]vidence shall be admissible if the
military judge determines that the evidence would have probative value to a reasonable
person" and "[e]vidence shall not be excluded from trial by military commission on the
grounds that the evidence was not seized pursuant to a search warrant or other
authorization." While the MCA correctly excludes all statements obtained by use of
torture, the MCA also tackles the hard question of statements taken from an illegal enemy
combatant where a "degree of coercion is disputed." Such statements may be admissible
under strict guidelines depending on when they were obtain ed. Statements obtained
before the enactment of Detainee Treatment Act "in which the degree of coercion is
disputed may be admitted only if the military judge finds that (1) the totality of the
circumstances renders the statement reliable and possessing sufficient probative value;
and (2) the interests of justice would best be served by admission of the statement into
evidence." Statements obtained after enactment of Detainee Treatment Act in which the
degree of coercion is disputed may be admitted only if the military judge finds that in
addition to (1) and (2) above, "(3) the inteiTogation methods used to obtain the statement
do not amount to cruel, inhuman, or degrading treatment."
Ironically, some view the common sense evidentiary provisions in the MCA as a
violation of Common Article 3's requirement that the accused be afforded all the
necessary "guarantees ... recognized as indispensable by civilized peoples." Such
ethnocentric views are quickly dispelled when one considers the day-to-day activity of
most modem European criminal courts where hearsay is regularly consi dered and far
different legal avenues regarding the introduction of evidence are regularly employed.
Even the International Ctiminal Court allows hearsay. In fact, earlier calls by some
(uniformed judge advocates who should have known better) that a military commission
should include the same due process standards that American soldiers enjoy at a military
courts martial under the Uniformed Code of Military Justice were wisely disregarded by
Congress. Obviously, these "relaxed" provisions in the MCA are necessary due to the
exigencies of war- witnesses and victims may be dead, investigators are not able to get

to the crime scene, etc. The MCA does provide the following rights for the accused who
is charged:

a copy of the charges in English and a language he understands;
a presumption of innocence for the accused;
guilt must be proven by the government beyond a reasonable doubt;
access to evidence that the prosecution plans to present at trial;
access to evidence known to the prosecution tending to exculpate the accused;
right to remain silent;
right to testify subject to cross-examination;
right to obtain witnesses and documents for defense;
right to present evidence and cross-examine witnesses;
the appointment of interpreters to assist defense;
right to be present at every stage of trial (except when proceedings are closed by the
Presiding Qffjcer) unless disrup6ve;
access to sentencing evidence;
cannot be tried again by military commission once verdict is final;
right to submit a plea agreement;
two-thirds of the military officers on the panel must agree on findings of guilt;
unanimous decision for death sentence;
right to a free military attorney or to hire a civilian attorney;
trial would be open to public (exceptions recognized for physical safety of

As various legal challenges to pottions of the MCA make their way through the lower
courts, e.g., the MCA revokes all U.S. court's jurisdiction to hear habeas corpus petitions
by alien enemy combatants in U.S. custody, it is highly doubtful that the Supreme Court
will strike down very much of the MCA as unconstitutional. Indeed, in time of war the
Court has traditionally been most reluctant to intervene in matters of national security,
particularly when the executive and legislative branches have joined together in such a
seamless fashion.
Prior to the MCA, Congress had seemed content to sit on the sidelines in the War on
Terror. While rational people understand that the unique threat of al-Qa'eda-styled
terrorism can only be addressed by employing the laws established for armed conflict, it
is equally true that said laws of war need to be updated to encompass the new paradigm.
For over five years, Congress has simply watched as the execu6ve branch, with
occasional mandates from the judicial branch, crafted and implemented an emerging rule
of law. It was extremely suppottive of the rule of law and vital to the issue of legitimacy
that the legislative branch of the government finally joined the process.

III. Preemptive Prosecution
A constant dilemma for the government in prosecuting Islamic militants is the need to
protect national security concerns associated with intelligence gathering while providing
the defendant with the full range of rights accorded by the Constitution. By Jaw and
custom federal prosecutors are authorized the discretion to decline cases brought to them
by investigative agencies.

Providing material support to terrorists
18 U.S.C.A. §2339A (West 2000 & Supp. 2004)
a) Offense-Whoever provides material support or resources or conceals or disguises the
nature, location, source, or ownership of material support or resources, knowing or
intending that they are to be used in preparation for, or in carrying out, a violation of
section 32, 37, 81, 175, 229, 35 1, 831, 842(m) or (n), 844(t) or (i), 930(c), 956, 1114,
1116, 1203, 1361, 1362, 1363, 1366, 175 1, 1992, 1993, 2155, 2156, 2280, 2281, 2332,
2332a, 2332b, 2332f, or 2340A of this title, section 236 of the Atomic Energy Act of
1954 (42 U.S.C. 2284), or section 46502 or 60123(b) of title 49, or in preparation for, or
in canying out, the concealment of an escape from the commission of any such violation,
or attempts or conspires to do such an act, shall be fin ed under this title, imprisoned not
more than 15 years, or both, and, if the death of any person results, shall be imprisoned
for any term of years or for life . ...
(b) Definiti on- In this section, the term "material support or resources" means currency
or monetary instruments or financial securities, financial services, lodging, training,
expert advice or assistance, safehouses, false documentation or identification,
communications equipment, facilities, weapons, lethal substances, explosives, personnel,
transportation, and other physical assets, except medicine or religious materials.

According to unclassified sources, from September 2001 until August 2006 investigative
agencies have characterized nearly 6,500 individuals arrested as "international terrori sts."
Of that number, 1,329, or 27%, were convicted in federal dist1ict courts. Only 14
received a sentence of 20 years or more in confinement, with 67 receiving sentences of
five or more years and 327 receiving sentences less than one year. 704 received no
confinement. Although the 1,329 were design ated as "international tenorists" by the
Justice Department, the actual crimes they were charged with often had no direct
connection to terrorist activity. The primary lead charges for these international terr01ist
cases were 18 U.S.C. § 1001 (fraud/false statements), 14.5%; 18 U.S.C. § 2332
(terrorism, criminal penalties), 14.4%; 18 U.S.C. § 2339 (providing material support to
terr01ists), 11.6%; 18 U.S.C. § 2371 (conspiracy to commit an offense or to defraud the
U.S. government), 4.7 %; and "not stated," 17.7%. In turn, the top lead charge from those

convicted of some crime was 18 U.S.C. § 1001 (fraud/false statements), 56.8%.
Interestingly, only one American, Adam Gadahn (aka Azzam al-Amriki) has been
charged with treason, making him the first U.S. citizen charged with treason since WW II
(seditious conspiracy charges were used against the terrorists who conducted the 1993
bombing on the World Trade Center). Gadahn converted to Islam in 1995 and later
moved to Pakistan where he has since appeared in a series of videos, calling for terrorist
attacks on Americans. Treason, the only crime spelled out in the Constitution is codified
at 18 U.S.C. § 2381. The indictment alleges that Gadahn, owing allegiance to the United
States, knowingly adhered to al Qa'eda and provided it aid-and-comfort, with intent to
"betray the United States." The indictment then provides extensive quotations from five
separate al Qa'eda videos in which he appeared and urged others to attack the United
States. He is also charged with providing material support in violation of 18 U.S.C.
The violation of immigration Jaws served as the primary authority for the FBI and
immigration officials to detain approximately 1,000 individuals across the United States
in the wake of the 9/11 terrorist attacks. Within four months, about two-thirds of those
detained accepted vol untary departure orders or were deported. It is unclear how many of
these deported illegal aliens actually were terrorists or had firm links to militant Islamic
groups. However, in the past six years, the FBI has broken up numerous al-Qa'eda and
al-Qa'eda-styled sleeper cells in the United States. One major radical Islamic terrorist cell
operating in the Detroit area was broken up in late August 2002 and four extremists were
charged. In September 2002, another terrorist cell in New York was broken up by the
FBI, leading to the arrests of six Arab-Ame1icans who had trained in al-Qa'eda terror
camps in Afghanistan in the summer of 2001. All were subsequently convicted under the
material support provisions. In October 2002, six more suspected terrorists were arrested
in Oregon (the so-called "Portland Seven") and Michigan. Four members were indicted
in federal court in Oregon on charges of trying to join or help the Taliban and al-Qa'eda
in Afghanistan wage war on the United States. In 2005, federal authorities broke up an alQa'eda cell in Lodi, California, when they arrested a father and his son as part of a larger
investigation. In September 2005, the FBI aJTested an Egyptian man suspected of plotting
the bombing of an airpo1t or plane, but only charged him with wire fraud and the
fraudulent use of a social security card. In 2006, an al -Qa'eda-styled group that was
plotting to bomb buildings was arrested in Miami, Florida.
In addition, the Justice Department has targeted institutions that provide financial and
logistical support to teJTor groups. In July 2004, for example, a Muslim charity called the
Holy Land Foundation for Relief and Development was closed by the government and
charged, along with seven of its officers, with supporting terrorist groups by illega11y
funneling millions of dollars to the tenorist organization Barnas.

IV. Iraq and the Future




Jeffrey F. Addicott, “CLE: 2007: Center for Terrorism Law Issues for Discussion,” St. Mary's Law Digital Repository, accessed February 21, 2019,

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