[Politech] Peter Swire on "Justice Intelligence Coordinating Council" [priv]

From: Declan McCullagh (declan@private)
Date: Wed Feb 25 2004 - 22:49:44 PST

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    From: "Peter Swire" <peter@private>
    To: "'Declan McCullagh'" <declan@private>
    Subject: RE: [Politech] DoJ announces "Justice Intelligence Coordinating 
    Council"
    Date: Wed, 25 Feb 2004 21:56:27 -0500
    
    
    Declan:
    
    	Having a Coordinating Council of this sort could be a helpful
    step, creating an institution that has oversight of intelligence
    activities and carefully considers the legal and civil liberties issues
    that arise from intelligence.  It is the sort of institutional check and
    balance that we need more of.
    
    	Unfortunately, the comforting words in the press statement don't
    turn out to be very reassuring. The statement says: "The Department Is
    Committed to Exercising Its Intelligence Functions within the Bounds of
    the Constitution, Laws and Guidelines that Protect the Privacy of
    Law-Abiding Americans."
    
    	Let's take those one at a time.
    
    	The Constitution.  The Supreme Court has basically said there is
    no "reasonable expectation of privacy" in records that are stored by
    third parties, such as your bank or phone company.  So the 4th Amendment
    warrant requirement currently does not apply to the vast array of
    digitally stored records.  Next, there may be widespread caching of VOIP
    and other phone conversations -- so stored records might come to phone
    calls themselves, eliminating the "reasonable expectation of privacy"
    even for wiretaps.  I have a new law review article called "Katz Is
    Dead.  Long Live Katz" on this subject,
    http://papers.ssrn.com/sol3/papers.cfm?abstract_id=490623.
    
    	Laws.  This is the realm of the Patriot Act.  Section 215 says
    there can be secret, binding searches for any record or other tangible
    object. It is a criminal violation even to tell that such a search has
    occurred.  Plus, the broader scope for National Security Letters in
    Section 505 allows the government to secretly get many records without
    any order from a judge. In addition, the Administration has sought to
    expand the scope of NSLs, including for use by the CIA and the Pentagon
    to search domestic records.  See Eric Lichtblau & James Risen, "Broad
    Domestic Role Asked for C.I.A. and the Pentagon," N.Y. Times, May 2,
    2003.
    
    	Guidelines.  Attorney General Levi in 1976 (under President
    Ford) issued substantial guidelines that, among other things, limited
    the ability of the FBI to open investigations based on protected First
    Amendment activities.  Attorney General Ashcroft in 2002 very
    substantially cut back on these restrictions.  There is a careful
    comparison by Jim Dempsey and Jerry Berman at
    http://www.cdt.org/wiretap/020626guidelines.shtml.
    
    	In short, it sounds very good to have protections by "the
    Constitution, the laws, and the Guidelines."  The protections in all
    three have shrunk substantially in recent years, though, so the
    reassuring language deserves a large grain of salt.
    
    	We likely should have the Coordinating Council as well as better
    actual protections in the Constitution, the laws, and the Guidelines.
    
    	Peter
    
    Prof. Peter Swire
    Moritz College of Law of the
         Ohio State University
    John Glenn Scholar in Public Policy Research
    Formerly, Chief Counselor for Privacy in the
         U.S. Office of Management & Budget
    (240) 994-4142, www.peterswire.net
    
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