Monday, March 17, 2008

Cruel, Inhuman or Degrading Treatment and the Right to Keep and Bear Arms

In his post on Friday, my new co-blogger Ori Herstein takes issue with Jeremy Waldron's reading of the language in various human rights documents prohibiting "cruel, inhuman or degrading" treatment. The colloquy in the comments---between readers, including Waldron himself, and Herstein---is well worth reading. The question that divides Herstein, Waldron, Marty Lederman, and others is whether an authoritative text forbidding "A or B" forbids conduct that is just A and also forbids conduct that is just B (Waldron and others) or whether it only forbids conduct that is "A and B" (Herstein).

At first blush, Waldron seems obviously right about this as a matter of simple logic. Forbidding "A or B" means forbidding that which is A or that which is B. If someone says "I'd like strawberry sorbet. I don't want coconut sorbet or lemon sorbet," it would be inaccurate to say you could abide her wishes by providing her a dish of coconut sorbet so long as it contained no lemon sorbet also. Likewise, if the same sorbet aficionado says she "detests coconut and lemon sorbet," we would ordinarily think that she detests coconut sorbet and she detests lemon sorbet, although it's conceivable that this usage means only to impart that she detests coconut and lemon sorbet in combination.

As Lederman's comment notes, how we parse the various texts relating to "degrading" and like treatment of persons matters most for questions about detainees---and Waldron's lecture indeed focused on such issues. But the question of how to read language of this sort arises in other contexts as well. For instance, does a punishment survive scrutiny under the Eighth Amendment if it is undoubtedly "cruel" but sufficiently widespread that it is not "unusual?" Most prominently, tomorrow the Supreme Court will hear oral argument in District of Columbia v. Heller, in which the question is how to read the "right to keep and bear arms" in the Second Amendment.

Following the "Waldron logic" from above, we would say that this language protects a right to "keep arms" that is separate from the right to "bear arms." Such a reading would surely favor respondent, because it would neutralize the argument of the petitioner that circa 1791 the term "bear arms" was overwhelmingly a reference to military service rather than a generic way to say something like "use weapons for whatever purpose." To be sure, the respondent ALSO argues that the term "bear arms" was sometimes used to mean just that, pointing, among other places, to state constitutions, but these were nonetheless unusual uses of the term. The District points out in its brief that EVERY reference to the term "bear arms" in the Congressional debates over what became the Second Amendment was a reference to military service.

But so what? There is also a separate right to "keep" arms, the respondent argues, and keep has its natural meaning, which is to possess.

Here is where, in my view, the Herstein approach makes considerable sense. As Herstein explains in one of his comments, his is an "interpretive" approach. I take this to mean---and in any event I think it is correct to say---that we give meaning to the various terms in the canonical formulation of the right at issue by reference to its neighbors. Suppose the Constitution contained a freestanding provision stating "The right of the people to keep arms shall not be infringed" and another freestanding provision---perhaps one enacted at a different time---stating "A well regulated militia, being necessary to the security of a free State, the right of the people to bear arms shall not be infringed." In that case, we might well think that the most natural reading of the right to keep arms is a right to personal possession and use of firearms. But married as it is to the "bear arms" provision, with its introductory text, we should be tempted to read "keep" as connected to militia service as well.

In the end, then, the Herstein reading is not at all illogical. He agrees with Waldron that a prohibition on "cruel, inhuman or degrading treatment" means something different from a prohibition on just cruel treatment, or just inhuman treatment or just degrading treatment. What he is saying---and I agree---is that the different thing that the concatenation of these three prohibitions means is not necessarily a prohibition on the totality of what each of the terms would prohibit separately. Herstein's point boils down to the notion that the meaning we give to the words of an authoritative text depends on the context of those words. Even self-described textualists happily accept this notion.

Posted by Mike Dorf

22 comments:

Carl said...

Following the "Waldron logic" from above, we would say that this language protects a right to "keep arms" that is separate from the right to "bear arms."

I don't think there's anything in "Waldron logic" - which seems to be nothing other than standard, first-order truth-funcational logic - that commits him to this interpretation. The grammar of the second amendment is logically ambiguous. It could be referring to both a "right to keep arms" and a "right to bear arms." But there is nothing in "Waldron logic" to prevent him from reading it in your preferred way as referring to a single right to "keep-and-bear arms," where the "and" in the predicate is not playing its usual role as a logical connective, but is serving as means of forging a unitary predicate that cannot be decomposed into its component parts.

Even assuming there is a similar ambiguity in the right to be free from inhuman or degrading treatment, however, Herstein's argument only works if we also assume both that the disjunction is being used to create the unitary predicate "inhuman-or-degrading treatment" AND that it expresses the same thing as the unitary predicate "inhuman-and-degrading," which I find dubious at best.

egarber said...

He agrees with Waldron that a prohibition on "cruel, inhuman or degrading treatment" means something different from a prohibition on just cruel treatment, or just inhuman treatment or just degrading treatment. What he is saying---and I agree---is that the different thing that the concatenation of these three prohibitions means is not necessarily a prohibition on the totality of what each of the terms would prohibit separately.


If we're dealing with "OR", how does one figure out when the holistic view is applicable?

Take the habeas corpus provision in the constitution:

The privilege of the Writ of Habeas Corpus shall not be suspended, unless when
in Cases of Rebellion or Invasion the public Safety may require it.

Nobody would say that "rebellion" hinges on whether it's qualified by "Invasion", I don't think.

Or the Fifth Amendment:

nor shall be compelled in any
criminal case to be a witness against himself, nor be deprived of life,
liberty, or property, without due process of law;

It seems the holistic view would mean that the definition of "liberty" hinges in some way on what we mean by "property".

I guess the easy answer is to look at these things case by case. But still, it seems to me we run the risk of being arbitrary without extreme care.

Michael C. Dorf said...

In response to both carl and egarber: I'll let Ori speak for himself but it seems to me that his point certainly CAN hold for disjunctive language too. The term "privileges and immunities" appears in Art. IV of the original Constitution, while the phrase "privileges or immunities" appears in sec. 1 of the Fourteenth Amendment. The former term had come to be a term of art in which "privileges" informs "immunities" and vice-versa. It is very straightforward to read the latter term this way too, given that the shift from "and" to "or" was simply stylistic to accompany a shift from an affirmative grant of a right to a negative limit on state action.

I do agree with carl's additional observation that the "Waldron logic" is indeed standard logic, but my point was that the "Herstein logic" is not therefore illogical, and in many cases, a more natural way to read legal texts.

Ori Herstein said...

Yes, I think generally the exchange following my original post has been overly focused on the conjunctive/disjunctive distinction. As I tried to explain, by the word “and” I meant that each term should be interpreted in a way that takes the other into account. I assume that usually each term, on its own, will dominate the regulation of conduct that falls within its meaning (i.e., the interpretive outcome will look like a disjunctive rule). However, on occasion, two or more terms, sharing a close legislative context, will influence the interpretation of each other. In cases where both terms apply to the same conduct, the prohibition is a function of our interpretation of the overlap. As I said, the overlap is not complete (if it were, there would be no reason to use two different terms). In addition, in interpreting vague terms, legal standards and terms of a constitutional nature (such as “inhuman” and/or “degrading”), I think that the holistic approach is more applicable and will differ from the atomistic approach more often than it will in cases of legislation that is more technical and subject to more rapid legislative revision. Usually, in the latter type of cases the choice of interpretive approach makes less of a difference than it does in the former cases.

Carl said...

The term "privileges and immunities" appears in Art. IV of the original Constitution, while the phrase "privileges or immunities" appears in sec. 1 of the Fourteenth Amendment. The former term had come to be a term of art in which "privileges" informs "immunities" and vice-versa

This is just standard application of De Morgan's laws. If we have a right to both A and B, it is violated is either A or B is withheld. The fact that the drafters of the 14A used the disjunction rather than the conjuction is highly suggestive of the fact that they read the original language as using "and" as a standard logical connective. Whether this was the right reading or not is beside the point. If the drafters of the 14A had read the original language as a unitary predicate, they would have presumably preserved its grammatical form. They didn't, and the fact that WE may read the original text as using such a predicate does not mean that "or" can in fact be used interchangeably with "and" in creating such predicates.

my point was that the "Herstein logic" is not therefore illogical

I was not suggesting that standard logic could not accommodate Herstein's view - that was the point of my discussion of the 2A. My concern was with the logic of Herstein's "unitary predicates" (or whatever term he prefers). If this approach even makes sense for predicates of the form "X-or-Y," surely this cannot mean the same thing as unitary predicates of the form "X-and-Y."

Richard said...

Having read Herstein’s post, Dorf’s post, and the discussion that followed, it seems to me that there are several distinct issues that are being dealt with together. As a result, I am a bit puzzled about the nature of the disagreement under discussion. In this comment, I will try to specify what seems to me the main issue that Herstein raised in his post. Please correct me if I misconstrue the dialectics.

It seems to me that everyone agrees that there are (at least) two possible interpretations for a rule that prohibits "inhuman and degrading treatment.” According to one interpretation, this rule prohibits inhumane treatment and it prohibits degrading treatment. In other words, a rulebook that contains this rule is equivalent to a rulebook that contains two separate rules: one prohibiting inhumane treatment and another prohibiting degrading treatment. Herstein calls this “the atomistic approach,” and he attributes this view to Waldron.

According to an alternative interpretation this rule prohibits only those acts that constitute both inhuman AND degrading treatment. In other words, a rulebook that contains this rule is NOT equivalent to a rulebook that contains two separate rules: one prohibiting inhumane treatment and another prohibiting degrading treatment. Hertein calls this “the holistic approach,” and Waldron calls this “the single predicate” approach. Herstein claims that the holistic approach “is warranted.”

I did not attend Waldron’s talk, but from the discussion it seems clear that there is no dispute about the intelligibility of both approaches. Waldron writes on the holistic approach that “of course it is a possible approach,” and Herstein surely would not deny that one could interpret the “and” in a rule that prohibits inhuman and degrading treatment as a simple conjunction of predicates.

So what is under dispute? And how are we to adjudicate between these two possible approaches?

Here’s how I understand the issue: Everyone will grant that inhuman and degrading treatment of humans should be prohibited. But how should we interpret this claim? Hertein proposed an example of an action that he believes should not be prohibited, and yet would be prohibited according to the atomistic interpretation. The example Herstein proposed is Jewish male circumcision. According to Herstein, circumcision is inhumane but not inhuman-and-degrading. If Herstein is right about all this (that circumcision should not be prohibited, that circumcision is inhumane, and that circumcision is not inhumane-and-degrading), then we have reason to prefer the holistic approach, since the holistic approach gives the correct result in this case, while the atomistic approach gives the wrong result.

Now surely the atomist has some wiggle room here. The predicates “inhumane” and “degrading” are vague, and one could try to play around with their boundaries in order to generate the correct result about the case described. At this point we will have to decide which solution is preferable (i.e., the holistic solution, or the wiggled-atomistic solution). Waldron, in his comments, indicated that in his talk he gave his “reasons for dissenting from [the holistic] approach.” It would be interesting to hear what his reasons are.

In any case, as I understand it, Herstein’s imaginative proposal invites us to try to come up with other cases that might help us adjudicate between these two interpretative approaches. Indeed, Dorf offered examples that seem to favor the holistic approach in this post. Can anyone think of other cases that the atomistic approach will get wrong? Alternatively, can anyone think of reasons to reject the holistic approach?

egarber said...

Waldron, in his comments, indicated that in his talk he gave his “reasons for dissenting from [the holistic] approach.” It would be interesting to hear what his reasons are.

If I'm not mistaken, I think Waldron was only talking about rejecting the holistic approach for an "OR" clause in that comment.

He says:

"I agree with Lederman, that Herstein's observations are very strange given that the ICCPR, the UNCAT, the ECHR, and the US Detainees' Treatment Act all talk about "inhuman OR degrading treatment," not "inhuman and degrading treatment."

If Herstein was at the lecture, he would have heard me mention the approach of the UNHRC which IS to treat "cruel, inhuman, or degrading treatment" as a single predicate (CID); and he would have heard my reasons for dissenting from that approach."

Michael C. Dorf said...

richard nicely summarizes what is and isn't at stake. two further points:

1) My examples were not meant to show that the holistic approach is always better, either as a way of retrieving speaker's meaning, or as a way of reaching the best results in concrete cases. I simply wanted to illustrate that Herstein's approach is sometimes best.

2) I want to distinguish two versions of holism. The "strong" version of holism says that "A and B" is a kind of unitary phrase in which we should not parse the individual terms. A practice is either "cruel and unusual" or it is not. We're not interested in whether it's just "cruel" or just "unusual" or even whether it's both "cruel" and "unusual." I think it possible to take the strong holistic approach even for language that uses an "or" but it is generally more sensible to do so with an "and." The more natural reading of a prohibition on "inhuman or degrading" treatment is that it prohibits treatment that is just inhuman and also prohibits treatment that is just degrading (and since "or" is by default "inclusive or," it also prohibits treatment that is both inhuman and degrading). But there is also what I would call a "weak" holistic view that says even though the prohibition forbids treatment that is just "inhuman" and treatment that is just "degrading," our understanding of what the terms "inhuman" and "degrading" mean should be influenced by their use together in the phrase "inhuman or degrading." I took Herstein to be defending only the weak holistic view.

egarber said...

How about the First Amendment as an example of weak holism at play?

Congress shall make no law respecting an establishment of religion, or
prohibiting the free exercise thereof
; or abridging the freedom of speech, or
of the press; or the right of the people peaceably to assemble, and to petition
the Government for a redress of grievances.



Simplifying the language, we could say, “Congress can’t promote religion or deny the right to it”.

Viewed in total isolation, the “establishment” prohibition might imply that a person can’t carry a bible in his book bag at a public school. It’s only through the “free exercise” clause that we can temper what the first prohibition means – and thus conclude that taking bibles away from individuals goes too far. So clearly in this case, one informs the other, even with disjunctive language.

Carl said...

Alternatively, can anyone think of reasons to reject the holistic approach?

I offered one counter-example in response to Ori's original post. If Ori is correct in suggesting that what makes some treatment degrading depends in part on the attitudes of the agents or on the role the treatment plays in some social system, his holistic approach would improperly permit any form of torture in which the goal was not to degrade the victim, but to purify or otherwise reform them.

As it stands, however, I agree with egarber that the real issue here is how Ori gets from a prohibition on inhuman _or_ degrading treatment, whether interpreted holistically or atomistically, to a prohibition on inhuman-and-degrading treatment interpreted holistically.

heathu said...

Oral arguments on the Right to Keep and Bear Arms are tomorrow, and I have a question: Should Scalia recuse himself from the Heller case? He has already expressed a view supporting the individual-rights model, and went as far as saying that the 2nd Amendment should not apply to the states. Antonin Scalia, A Matter of Interpretation: Federal Courts and the Law, 136-137, n. 13, (1998). I am asking because he felt the need to recuse himself from Elk Grove Unified School District v. Newdow (the pledge of allegiance case) when he expressed criticism of the lower court's holding. http://www.law.com/jsp/article.jsp?id=1066080440869. And if he doesn't recuse himself in Heller, what's the difference?

Neil H. Buchanan said...

As another example, I have always understood the term "arbitrary and capricious" in the "strongly holistic" sense.

hahamoudi said...

I tend to be far too dismissive of this sort of highly nuanced lexical dissection as being in any way related to interpretive process to be of much use here, but I would say one thing in favor of Herstein's proposal. When I say before my contracts exam "no notes, law review articles or books permitted", I think they know I don't care about their wedding albums. And if I were to say in an art class, "no drawings, photos, paintings or books", they know I don't care about an unillustrated law review article. Words carry inherent ambiguity, it doesn't make much sense to me to suggest that just because there is a disjunctive, that the words are atomized in a way that makes them wholly separate from each other. Though I do quite agree, one can claim to adopt an atomized approach and then just wiggle the meaning of the terms to get the same result. Which is why I'm not sure any of this is really relevant or determinative in any case ever, but pardon my Realist cynicism.

Carl said...

When I say before my contracts exam "no notes, law review articles or books permitted", I think they know I don't care about their wedding albums.

While we certainly rely on context to convey much of mean to say, the phenomenon you mention has nothing at all to do with whether we interpret "no books or notes" as one predicate or two. Either way, context will have to be used to delimit your meaning. There is nothing magical about using a single predicate to convey meaning. Suppose your instructions were simply "no books." The mere fact that you used a single predicate does not logically entail that you don't actually care about wedding albums. This is something that is understood from the context, and the rules of conversational implicature apply no matter how we choose to express ourselves or what we think the appropriate logical form of our statements is. This is not to say, of course, that there are not significant differences in meaning between unitary predicates of the kind Ori is arguing for and their binary alternatives, but merely that neither in principle is better equipped to express the extra-linguistic facts that can only be derived from sensitivity to context.

hahamoudi said...

Actually, I think Ori's approach is better equipped to determine context than any binary approach. Really perhaps the best example to my own mind are force majeure clauses, which I know much better than that which we are discussing, actually. (Which means most of what I am saying can probably safely be ignored).

These clauses have long lists of activities that, when they render performance impracticable, excuse it (tornadoes, floods, lightning, earthquake) and then follow with something to the effect of "or any act of God or nature or any act of government or civil commotion".

Now if one really wants to atomize these items into separate categories because of the disjunctive, they can, but "act of nature" could then refer, for example, to shifting subsoil conditions that make it much more expensive to build a power plant, and "act of government" could refer to seemingly quite high levels of taxation. I think when courts and arbitrators almost uniformly (in my experience) reject these broad readings, and look to "context", they effectively employ something similar to the Herstein approach, which is to look at the list of items and to glean from it a "holistic" set of permissible excuses (windstorms count, taxes don't). I'm not sure in these cases how else context is determined other than by looking at the list as a composite whole rather than as entirely separate items bearing no relationship to each other.

Carl said...

Actually, I think Ori's approach is better equipped to determine context than any binary approach.

I see what you are suggesting. To return to your earlier example, you are arguing that the fact that you are specifically excluding books, class notes, and law review articles does as much to delimit the class of impermissible materials as the extra-linguistic fact that you are giving a contracts exam. I think this is correct, but I'm not sure that the strategy of interpreting speaker's meaning by looking at the relationships between some word and the words surrounding it turn on how we interpret the logical connectives. Whether we read your instruction as either "a prohibition on bringing books to the exam and a prohibition on bringing law review articles to the exam" or "a prohibition on bringing books-and-law review articles to the exam" doesn't seem to me to settle the issue of whether a student can bring a wedding album so much as the fact that it's a contracts exam and you prohibited both books and law review articles. The fact that we interpret the logical connectives in their binary sense does not preclude us from interpreting the two conjuncts holistically and in relation to each other. Surely there is nothing to prevent us from interpreting the meaning of a prohibition on books and a prohibition on law review articles by looking to both their semantic and their extra linguistic contexts. Or to put my point more succintly, I think it's important to distinguish between the atomistic-holistic distinction, which is matter of hermeneutics, and the uniary-binary distinction, which is a matter of logic. Binary predicates can be interpreted holistically, while uniary predicates can be interpreted atomistically. Which interpretation is correct frequently depends on context, including extra-linguistic information. The only reason the logical distinction has been impicated here is that some of us have taken issue with Ori's forming a unitary predicate out of a binary disjunct. Otherwise, I would agree with you that the issue has little to do with the interprtive process.

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