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thedrifter
05-04-05, 07:27 AM
05.03.2005

Military Discipline vs. Constitutional Rights


By Michael S. Woodson



As the U.S. military prepares to resume its controversial mandatory anthrax vaccine immunization program for the troops, any personnel who may later allege injury or harm from the vaccine face a nearly impassable barrier to seeking redress through monetary damages by lawsuits in the federal courts. If troops objecting to the vaccine are unable to stop the program by obtaining injunctions against the program, it appears they will have no recourse for unconsented injuries caused by the vaccine unless Congress grants adequate compensation by statute.



Although the federal government has in the past created special compensation programs to help victims, airlines, security firms, insurers and re-insurers cope with 9/11, our troops do not enjoy similar regard when failures in government or corporate judgment regarding terror threats lead to injuries or debilitating illnesses. Here, the controversy is over whether the cost of the anthrax vaccine outweighs its benefits considering the likelihood of anthrax exposure.



And if one previous decision by the Supreme Court were to occur again, the Pentagon may even be free to administer the vaccine to troops surreptitiously and get away with it.



It was, in my opinion, a U.S. Supreme Court decision ranking with the worst of them. The case before the high court in 1987, U.S. v. Stanley, illustrates that the court has already ratified the constitutionality of the elitist abuse of enlisted personnel.



Treating the doctrine judicial restraint as more important than the substance of the Constitution itself, Justice Antonin Scalia opined for the majority of the Supreme Court in Stanley that former U.S. Army Master Sgt. James B. Stanley could not sue the Army or military officers for monetary damages after they treated him like a laboratory rat and tested the military effects of LSD on his body and mind without his consent or knowledge.



The Stanley decision held that where an enlisted person's injury was "incident to" or "arising" out of his military service, he or she could not sue the military for compensation. One wonders how military service or discipline could ever include civilian and/or military leaders fraudulently and secretly introducing LSD into the body of a U.S. Army NCO and concealing the fact. Common sense tells us that such an act would erode trust and discipline in the ranks.



In February 1958, Stanley had volunteered for a program pitched by the Army described as as a chemical-warfare-gear-testing experiment. Instead, project managers all along dosed him with LSD without his knowledge or consent.



Stanley was not told until decades later. His subsequent lawsuit charged that psychiatric symptoms from LSD poisoning caused him to suffer recurring hallucinations that led him to attack his wife. This destroyed his marriage and brought him untold mental suffering as he lived with the uncertainties caused by his symptoms. Who can measure the pain of one's own questioned sanity after the hallucinations came?



After reading a 2001 account in The New York Times magazine of CIA scientist Frank Olson's own death following a similar experience – Olson was given LSD without his knowledge and later died when he fell or was thrown from a hotel room in New York – Stanley's allegations seem almost mundane.



But the implications of the Supreme Court ruling against the NCO cast a dark shadow that falls over every man and women serving in the U.S. military today.



The strategic and constitutional goal of military discipline is to unify men and women to win wars in defense of the United States and to protect the Constitution. Practically, this discipline also exists to forge loyal order in the military chain of command. However, the real glue in the chain of command is earned trust.



In the name of protecting orderly military discipline, the Stanley decision helped to undermine this crucial trust. The worst blow to military morale and discipline in recent history came in the 1970s. It was not only from the damage done to the military from our disastrous experience in Vietnam, but as a result of revelations that the Army and CIA had conducted LSD, radiation, and chemical war experiments on U.S. enlisted personnel without their consent over the years.



The Stanley decision embraced the stock Cold War arguments popular among certain CIA elements that destroying trustworthiness was an acceptable price to pay in the name of "national security." Such was the dubious purpose of the CIA's MKULTRA program in the early 1950s that included the inhuman LSD experiments aimed at making a new and improved truth serum. Is the "war on terror" the new justification for experiments on soldiers?



In Stanley, Scalia excused the court from the red-hot issue by using the mere

existence, not exclusive language, of the power committed to the Congress to regulate the naval and land forces found in Article 1, Section 8 of the U.S. Constitution. A careful reading of Scalia's opinion shows that he relied not on that particular clause's plain language, but rather from the court's own activist reasoning in previous cases that that inferred an exclusion from the "positive power." The result was that Scalia argued away any meaningful judicial relief for the afflicted Army sergeant.



Other citizens have access to monetary damage suits when their remedies elsewhere are inadequate. However, Scalia's premise in Stanley was that enlisted personnel are not worth the large amounts of money that other people can get when they sue their government employers. He covered for that elitist premise by pretending to protect military discipline.



The Stanley case was about deciding the legal question of whether other mistreated former enlisted personnel could bring a suit in civilian courts for damages at all. Here, Stanley, after serving at risk to life and limb, going so far as to volunteer to test chemical warfare suits for the benefit of fellow soldiers, nearly losing his sanity and then losing his family to the after-effects of illegal government actions, was stonewalled with hair-splitting procedural ducking by the nation's highest court.



In February 1953, Secretary of Defense Charles E. Wilson had ordered the Army, Navy and Air Force to follow standards of informed consent set forth in the postwar Nuremberg Tribunal after Nazi medical experiments on human prisoners made the world gag in disgust. However, documents on file at George Washington University's National Security Archive show that some people in the United States missed the point of the Nuremberg trials.



Here is a final question for military minds and jurists to ponder. How do you suppose someone at an Army laboratory could be persuaded to so thoroughly deceive one of his own compatriots and poison him? Those at the Army facility, if not deceived themselves, probably rationalized that Stanley's consent to the dangers inherent in volunteering to test chemical warfare suits covered any danger posed by directly testing LSD on a subject without his knowledge.



Like so many trusting people who are wrongfully abused, Stanley probably believed that the chemical warfare suits would be state-of-the-art American technology that would protect him from whatever chemical agents were involved.



As we know today, it was Stanley's body, not the suit, being tested. It was his faithfulness to military orders that was betrayed. It was his nation's highest court that upheld the betrayal.



What is the continuing relevance of this case to today's troops? The U.S. District Court in Washington, D.C., early last month "modified" a five-month-old injunction that had halted the DoD Anthrax Vaccine Immunization Program (AVIP) on grounds the Food and Drug Administration had not promulgated sufficient public notice about the original program. Some observers expect the modification to result in resumption of mandatory vaccinations sometime this year.



Given the ongoing controversy over adverse effects of the anthrax vaccine, a review of U.S. v. Stanley is not encouraging for today's potential medical guinea pigs wearing their nation's uniform.



Congress must pass a law that requires informed consent whenever any experimental drug or process is to be applied to our troops. The should give the troops and veterans a route to meaningful monetary compensation in courts without a conflict of interest if such experimental actions violate their rights. At risk is our nation's legitimacy as a trustworthy democracy that practices at home what it preaches to the world.



Ellie

law_student
05-05-05, 08:33 AM
My understanding is that Congress has already passed a law requiring informed consent for investigational drugs. 10 USCS § 1107.

Then, President Clinton issued Ex. Or. No. 13139 of Sept. 30, 1999, 64 Fed. Reg. 54175, which required informed consent for investigational drugs. However, the president can waive the informed consent requirement if necessary.

May 3rd, the same day as the Woodson article, DoD announced the resumption of anthrax vaccinations. DoD plans to provide an education and information program highlighting the FDA's decision to provide for emergency vaccinations.

According, to the Sec Def's April 29th directive, service members can still refuse the shots.

Woodson is probably right that Congress should provide some sort of remedy for people like Stanley, but he is unfairly critical of the Supreme Court. Woodson ignores the procedural aspect of the case. Scalia is rejecting a claim based on the Federal Tort Claims Act (FTCA), using the same reasoning as the lower District Court (which was reversed by the 11th Circuit Court of Appeals -- it was the 5th Circuit before being split.). This isn't about elitist abuse of military personnel. This was the court's concern that allowing a FTCA claim to proceed would open the flood-gates to tort litigation, particularly when Congress has already provided a compensation system for veterans through the VA.

As for providing a monetary remedy, I think Stanley still would have had a claim for up to $100,000 under the Military Claims Act, 10 USCA § 2733. Also, I'm curious as to any disability benefits that he could have obtained. So, I don't think he was hung out to dry or that the system and courts are trying to hose us veterans.

While Stanley obviously was going for the big dollar punitive damages available in negligence cases, I still think fair compensation was available to him AND that Congress fixed the problem by requiring informed consent for investigational drugs.

Semper Fi,
Dan

You can find more info at: http://www.anthrax.mil/whatsnew/eua.asp

Also, the Stanley case is at 483 U.S. 669.

mike7woodson
11-14-07, 11:17 PM
My understanding is that Congress has already passed a law requiring informed consent for investigational drugs. 10 USCS § 1107.

Then, President Clinton issued Ex. Or. No. 13139 of Sept. 30, 1999, 64 Fed. Reg. 54175, which required informed consent for investigational drugs. However, the president can waive the informed consent requirement if necessary.

May 3rd, the same day as the Woodson article, DoD announced the resumption of anthrax vaccinations. DoD plans to provide an education and information program highlighting the FDA's decision to provide for emergency vaccinations.

According, to the Sec Def's April 29th directive, service members can still refuse the shots.

Woodson is probably right that Congress should provide some sort of remedy for people like Stanley, but he is unfairly critical of the Supreme Court. Woodson ignores the procedural aspect of the case. Scalia is rejecting a claim based on the Federal Tort Claims Act (FTCA), using the same reasoning as the lower District Court (which was reversed by the 11th Circuit Court of Appeals -- it was the 5th Circuit before being split.). This isn't about elitist abuse of military personnel. This was the court's concern that allowing a FTCA claim to proceed would open the flood-gates to tort litigation, particularly when Congress has already provided a compensation system for veterans through the VA.

As for providing a monetary remedy, I think Stanley still would have had a claim for up to $100,000 under the Military Claims Act, 10 USCA § 2733. Also, I'm curious as to any disability benefits that he could have obtained. So, I don't think he was hung out to dry or that the system and courts are trying to hose us veterans.

While Stanley obviously was going for the big dollar punitive damages available in negligence cases, I still think fair compensation was available to him AND that Congress fixed the problem by requiring informed consent for investigational drugs.

Semper Fi,
Dan

You can find more info at: http://www.anthrax.mil/whatsnew/eua.asp

Also, the Stanley case is at 483 U.S. 669.

Law student, thank you for commenting. In the statute you cite, what the big print gives, the small print takes away. This is not a requirement, it is a loophole and nothing in the statute bars the president from waiving informed consent as to a specific group of personnel at one time, and delegating statutory compliance rationale fulfillment to subordinates -- like the former AG.

"Under 10 U.S.C. 1107(f) the President may waive the prior consent requirement for the administration of an investigational new drug to a member of the armed forces in connection with the member's participation in a particular military operation." Source 21CFR50.23 (http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=50.23)

The statute you refer to can also be challenged as an unconstitutional invasion into the plenary powers of the Commander in Chief to control discipline in his Chain of Command, just as Stanley's attempted availment via the FTCA was challenged. It all depends on what sort of president you have at the time as to whether the deed (human experimentation) is desired and a legal challenge prepared for the Act (in some cases utilizing enthusiastic young law students who are later traumatized to discover what their research may have enabled).

You may have missed content within Stanley concerned with putting down interference with the chain of command and disciplined execution of orders given by officers senior. This interest, rooted in the CINC power, trumped Stanley's rights. Reread the piece and then reread Stanley.

Also, if what you say is true, that the Courts handling the Stanley case were primarily interested in preventing a flood of litigation in cases responding to situations in which the military had fraudulently used a service member as a guinea pig, then that would mean the military was using troops as guinea pigs on a large scale. A "flood" implies this, doesn't it? Are you suggesting that in such a situation, a flood of litigation shouldn't ensue?

Let's add another element: the Congress is peopled with a good many folks who receive campaign finance support from corporations and their employees at defense firms whose substances and systems would often be those tested on military personnel in the scenarios at issue here. And if the government were sued in tort, who do you think it would join for contribution or comparative liability if it were unsuccessful? The companies producing the agents. As the military or government counsel, I'll bet you'd recommend it. In any case, the litigation would be healthy because it would air the truth about what is being done that shouldn't.

I love this country. But I am not so naive as to believe that a person in a place of power who would use our own NCO's/enlisted/officers as guinea pigs in human experimentation in the first place would have any qualms about disobeying a statute, an executive order of the past, or God Himself if he came down and shook his head about the matter.

It seems also that we haven't examined the actual punishments readied by the statute for those breaching it, i.e. doing the experiments without passing the fact up the chain to the president. Are they deterrent, or a joke?

And we don't even see a bright line rule against bootstrapping in the president's waiver, that is, a subordinate creating a sheist-storm of such politically apocalyptic proportions for a president that it would force anyone less stalwart than Ike to save himself by ratifying the waiver after the fact.