Wednesday, October 24, 2012

The Centrality of the Ex Post Facto Clause

By Mike Dorf

My most recent Verdict column discusses last week's ruling by the DC Circuit in Hamdan v. United States. As I explain in the column, the court threw out Hamdan's conviction because the law under which he was charged criminalized violations of the law of war, but at the time of Hamdan's charged conduct, material support for terrorism--the charge brought against him--was not a violation of the international law of war.  I treat the ruling as an occasion to reflect upon the fact that more than eleven years after 9/11, the government still has not fully sorted out how to deal with detainees who are non-state actors.

Here I want to use the Hamdan case as an opportunity to raise some questions about the point of the constitutional prohibition on ex post facto laws.  The court construes the law under which Hamdan was charged as having no retroactive effect in order to avoid the constitutional question that would otherwise arise under the Ex Post Facto Clause of Art. I, Sec. 9.  Should we understand that clause as serving any function other than implementing the principle that no one may be criminally charged without notice that the conduct in which he or she engaged was prohibited?  If not, then the Ex Post Facto Clause is entirely redundant with the Due Process Clause.  But if it has some further content, what content might that be?

The original aims of the drafters and ratifiers are a useful starting point.  The records of the 1787 Convention indicate that the inclusion of the prohibitions on federal ex post facto laws (Art. I, Sec. 9) and state ex post facto laws (Art. I, Sec. 10), was mostly uncontroversial.  What opposition there was took two main forms: 1) Some thought that the ex post facto prohibitions were unnecessary because ex post facto laws are simply impermissible legislation (on something like natural law grounds); and 2) some thought that the prohibitions were dangerous insofar as they could be construed as barring retroactive civil legislation, which is, to some degree, unavoidable.  These objections were defeated on the respective grounds that: 1) an express prohibition is useful as a kind of insurance (see in particular Madison in Federalist 44); and 2) it would be understood that the clauses referred only to criminal laws, as a kind of term of art.

Thus I think it reasonably clear that the Framers regarded ex post facto laws as, in Hamilton's phrase in Federalist 84, among the "most formidable instruments of tyranny."  Why?  Well, that seems obvious enough.  A legislature that forbids conduct after it occurs can find anyone guilty of anything, because it deprives him of the opportunity to conform his conduct to law.  But is that consideration in any way independent of a right to notice, independently protected by the Due Process Clause of the Fifth Amendment?

From the framers' perspective, I think the answer is probably yes.  Today we think of the right to due process as including a right against certain classes of legislation as well as a right to certain sorts of procedures in concrete cases.  But circa 1787/1789/1791, the right to due process may have been thought to apply only in concrete cases.  It is thus notable that the Ex Post Facto Clauses can be found near the end of Article I, along with other provisions limiting the kinds of legislation Congress may enact, whereas the Fifth Amendment Due Process Clause can be found in the Bill of Rights, surrounded mostly by other rights against particularized actions.  (I say mostly, because some provisions of the Bill of Rights, such as the First Amendment, which poses a limit on the "law[s]" that "Congress" can "make," obviously are aimed at legislative abuses.) To paint with a broad brush, the founding era framers might not have thought of bills of attainder as violating due process; they would have thought of it as a legislative abuse instead.

Over time, notions of due process expanded to include what we now call substantive due process.  (For a useful description of that evolution during the first two-thirds of the 19th century, I recommend this article article by my former student Ryan Williams in the Yale Law Journal.)  But substantive due process was and remains controversial.  Less controversially, due process also came to be understood as generally limiting the content of legislation, including limiting retroactive legislation.  Accordingly, if the Constitution contained no Article I, Section 9 Ex Post Facto Clause today, all of the work that Clause does would be taken up by the Fifth Amendment Due Process Clause.

What about the Ex Post Facto Clause of Article I, Section 10, which binds the states?  Section 10 lists a number of limits on the states, most of which have to do with federalism and federal supremacy.  But three concern liberty: the Bill of Attainder Clause; the Contracts Clause; and the Ex Post Facto Clause.  (The oddball in the whole collection is the Title of Nobility Clause, which could be thought as an embryonic precursor to the Equal Protection Clause.)  Thus, at a time when the general view was that the federal Constitution did not need to set forth rights against the several states, one of the very few exceptions was the prohibition on ex post facto legislation.

Of course, today the Article I, Section 10 Ex Post Facto Clause is subsumed by the Fourteenth Amendment Due Process Clause, just as the Article I, Section 9 version is subsumed by the Fifth.  Should that trouble us?  I don't think so.  Instead, I would read the foregoing history as confirming two propositions.

First, it should remind us of the importance of notice to our constitutional understanding of the rule of law.

Second, the way in which the Constitution has become redundant should serve as a reminder that it is not the perfect Word of God.  Textualist or (to use a phrase coined by Akhil Amar) "intra-textualist" modalities of constitutional interpretation that attempt to mine every comma and semi-colon in the Constitution for hidden meanings likely overstate the importance of such phrasing choices to the framers and certainly overstate their importance to the People.

Now, it might be objected to that last point that I have unfairly taxed intra-textualism with redundancies that developed over the course of many years--that the juxtapositions that matter are the ones that were inserted into the text together, coming out of the same mind.  To which I say: why?  If the Constitution is supposed to be a work of genius, then shouldn't we expect later enacters to read it carefully before burying their new hidden meanings in its verbal interstices (like clues in a Dan Brown novel)?

My main point here is not to object to Amar's intra-textualism.  Judge Posner has taken that task for himself and done a much more detailed, humorous and, I daresay, vicious, job than I can.  And anyway, I don't even agree with most of Posner's criticisms.  E.g., I think Amar's reading of the Ninth Amendment is much more sensible and straightforward than Posner's--which attributes to its framers the goal of rebutting an inference that only an idiot would draw.  My main point here is simply to sing an ode (so to speak) to the Ex Post Facto Clauses.

28 comments:

Hashim said...

Your observation of redundancy would make sense if the general DP clauses were enacted before the specific EPF clauses. But it doesn't make any sense in the converse order, which is how the provisions actually were enacted.

The Framers originally enacted the EPF clauses because they were concerned about a very specific type of notice deficiency -- retroactivity. They then subsequently adopted broader DP clauses that encompass all sorts of notice concerns, as well as other (at least) procedural concerns.

What exactly were the later drafters supposed to do to eliminate the redundancy? It'd be pretty strange to repeal the EPF clauses just because they would now be subsumed w/in the new DP clauses. It'd be equally strange to point out in the new DP clauses that they recognized that at least some of its protections already existed because of the EPF clauses. And this is all especially true since both EPF clauses did not become redundant until 1868.

So this particular example does not even remotely undermine intra-textualism.

Joe said...

"to sing an ode"

Sing, O goddess ...

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sylvia keith said...

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maya nelson said...

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DR AZAZI said...

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5-Exam spell
6-Home problem Spell
7-Instant Death Spell
8-Famous Spell
9-Fruitfulness of a child
10-Lottery spell
In short contact him in any kind of spell is CONTACT ME VIA
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Olivia Tim said...

After years in marriage with my hubby and our 2 kids, my husband started going out with other ladies and showed me

cold love, on several occasions he threatens to divorce me if I dare question him about his affair with other

ladies, I was totally devastated and confused until a old friend of mine told me about a spell caster on the

internet Dr. eho who help people with the relationship and marriage problem by the powers of love spells, at first

I doubted if such thing ever exists but decided to give it a try, when I contact him, he helped me cast a spell

and within 48hours my husband came back to me and started apologizing, now he has stopped going out with ladies

and he his with me for good and for real. Contact this great spell caster for your relationship or marriage

problem at ehospellhome@yahoo.com Goodluck

maya anderson said...

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Santos Jenny said...

I was in love with a guy called Scott, we have been dating since 2008, we loved each other very well, i don't know what happen in August this year everything changed, he started cheating, he left me for another lady, though i pleaded with him, it was all in vain, i was ready to do anything to make sure i get him back, i contacted one fake spell caster unknowingly, he scammed of $1.500, still yet i moved forward, i contacted Dr. Kasabubu, he asked me to fill his temple form, i filled it and send it back to him, he told me that before he can cast the spell he need some items in which he will use, in casting the love spell, i sent him the items money, he bought the items and casted the spell within two days, after the spell has been done he told me that my Ex lover will come back to me within 24 hours, truly the next day, he came to my place and started begging for forgiveness, i forgave, we are happily together now, he proposed to me and we are getting married in January, 2014. i am very happy for his great work on my life, he alone can bring joy into your life, contact him via email kasabubuspellhome@hotmail.com.

lizzy baby said...


I want to testify to everyone on how my husband and i got children after our 5years of marriage. we got married and we could not conceive a child we have been to several hospitals for checking and the doctors always say that we are okay that nothing is wrong with us, we have been hoping for a child, my husband was beginning to keep late night outside and pressure from the family for him to marry another wife and divorce me, i was always crying and weeping because i was loosing my marriage. so i visited my friend in Florida and she told me that she also have been through this same situation but she got her help of getting her own child from a great dr okorom of fertility from Africa, so she told me that she will contact me to the dr okorom and he will do some fertility spell for me to have my own child, i spent 4days with her in Florida and we both email the dr okorom and he said i should bring all my information to him and he said in 2days after the spell will be completed. so i waited and i went back made love with my husband and i conceive. so i am very greatful to the dr okorom for his help and miracle that help me save my marriage. please for same help, conatct him on dr.okoromspellhome@live.com

faith jessica said...



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ELIZABETH ROSAS said...


Elizabeth Nicolas

After being in relationship with emma for seven years,he broke up with me, I did everything possible to bring him back but all was in vain, I wanted him back so much because of the love I have for him, I begged him with everything, I made promises but he refused. I explained my problem to someone online and she suggested that I should rather contact a spell caster that could help me cast a spell to bring him back but I am the type that never believed in spell, I had no choice than to try it, I mailed the spell caster, and he told me there was no problem that everything will be okay before three days, that my ex will return to me before three days, he cast the spell and surprisingly in the second day, it was around 4pm. My ex called me, I was so surprised, I answered the call and all he said was that he was so sorry for everything that happened, that he wanted me to return to him, that he loves me so much. I was so happy and went to him, that was how we started living together happily again. Since then, I have made promise that anybody I know that have a relationship problem, I would be of help to such person by reffering him or her to the only real and powerful spell caster who helped me with my own problem and who is different from all the fake ones out there. Anybody could need the help of the spell caster, his email: drinegbedionspellhome@gmail.con you can email him if you need his assistance in your relationship or anything. CAN NEVER STOP TALKING ABOUT YOU SIR HIS EMAIL ADDRESS IS:drinegbedionspellhome@gmail.com CONTACT HIM NOW FOR SOLUTION TO ALL YOUR PROBLEM










ELIZABETH ROSAS said...


Elizabeth Nicolas

After being in relationship with emma for seven years,he broke up with me, I did everything possible to bring him back but all was in vain, I wanted him back so much because of the love I have for him, I begged him with everything, I made promises but he refused. I explained my problem to someone online and she suggested that I should rather contact a spell caster that could help me cast a spell to bring him back but I am the type that never believed in spell, I had no choice than to try it, I mailed the spell caster, and he told me there was no problem that everything will be okay before three days, that my ex will return to me before three days, he cast the spell and surprisingly in the second day, it was around 4pm. My ex called me, I was so surprised, I answered the call and all he said was that he was so sorry for everything that happened, that he wanted me to return to him, that he loves me so much. I was so happy and went to him, that was how we started living together happily again. Since then, I have made promise that anybody I know that have a relationship problem, I would be of help to such person by reffering him or her to the only real and powerful spell caster who helped me with my own problem and who is different from all the fake ones out there. Anybody could need the help of the spell caster, his email: drinegbedionspellhome@gmail.con you can email him if you need his assistance in your relationship or anything. CAN NEVER STOP TALKING ABOUT YOU SIR HIS EMAIL ADDRESS IS:drinegbedionspellhome@gmail.com CONTACT HIM NOW FOR SOLUTION TO ALL YOUR PROBLEM










Grace George said...

My name is Mrs Grace, this is my story, After 9 years in marriage with my hubby with 3 kids, my husband started
going out with other ladies and showed me cold love, on several occasions
he threatens to divorce me if I dare question him about his affair with
other ladies, I was totally devastated and confused until a old friend of
mine told me about a spell caster on the internet Dr. Trust who help people
with the relationship and marraige problem by the powers of love spells, at
first I doubted if such thing ever exists but decided to give it a try,
when I contact him, Dr.OKAKA, he helped me cast a spell and within 24hours my husband
came back to me and started apologizing, now he has stopped going out with
ladies and he his with me for good and for real. Contact Dr OKAKA on his mail,
oviatample@gmail.com this great spell caster for your relationship or
marriage problem at: Good luck.

Dockey Baba said...

So I just consult the oracle and it has said the
list of items that is
needed before the spell can start working and they are,
two parrot,
carries (30),
red and black candle 1 packet each,
white cock,
a yard of black cloth,
native soap,
and two feather of bird,
native chalk,
1year old goat(male),
and a rabbit head .
So this are the
items needed for the
spell ok. So you have to try and get the items
and send them to me so
that I can proceed with your work ok. So you
have to feel free my
oracle is definitely going to help you so just
have the believe that
it shall be well with you okay
if you have any question or problem in getting these listed items, please let me know

Dockey Baba said...

If the future of your
relationship is in jeopardy and
past mistakes are still haunting
you, preventing the two of you
from being in each other's
arms, you should ask a Master Psychic to cast a Starting Over
spell for you.
Do These Questions Apply To
You?
Is your life empty without him?
Do you think of him often? Do you sometimes have trouble
going about your work because
he's on your mind?
Are you depressed because you
feel him slipping away?
Do you have a wealth of love stored up just for him?
Email: babadockeytemple@gmail.com

Dockey Baba said...

If the future of your
relationship is in jeopardy and
past mistakes are still haunting
you, preventing the two of you
from being in each other's
arms, you should ask a Master Psychic to cast a Starting Over
spell for you.
Do These Questions Apply To
You?
Is your life empty without him?
Do you think of him often? Do you sometimes have trouble
going about your work because
he's on your mind?
Are you depressed because you
feel him slipping away?
Do you have a wealth of love stored up just for him?
Email: babadockeytemple@gmail.com

Dockey Baba said...

If the future of your
relationship is in jeopardy and
past mistakes are still haunting
you, preventing the two of you
from being in each other's
arms, you should ask a Master Psychic to cast a Starting Over
spell for you.
Do These Questions Apply To
You?
Is your life empty without him?
Do you think of him often? Do you sometimes have trouble
going about your work because
he's on your mind?
Are you depressed because you
feel him slipping away?
Do you have a wealth of love stored up just for him?
Email: babadockeytemple@gmail.com

alex moore said...

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Beatrix Harvey said...

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Beatrix Harvey

Jolene Leslie said...

I have been in great bondage for almost 2 years suffering in the hands of a cheating husband,we were happy and leaving well until he meant his old time time gilr friend and he started dating her outside our marriage before you knew it he stooped caring and taking care of his own family it was to the extent that now he was planning to get married to her and divorce his own wife, i have cried and reported him to his family but he never listened to any one but to cut my story short i came in search for a real spell caster who could destroy their relationship and make him come back to his wife and 2 kids on my search i saw people making testimony on how their marriage where restored by Priest Ajigar i pick his email and i narrated my story to him and he agreed to help me and after performing a spell on the third day they both had a quarrel and he beat his girlfriend up and he came home begging for i and my little kids to forgive him that his eyes are clear now that he will never do any thing that will hurt his family again and promise to be a caring father and never cheat again.I am so so happy that i did not loose him to the girl all appreciation goes to Priest Ajigar for you are a Great spell caster and to whom this may concern if you have a cheating husband or wife you can as well email Priest Ajigar him on (priestajigarspells@live.com)

vodoo spell said...


Be careful here nobody can help you here or even suggest how you can get your ex or love back,any testimonies of most spell caster here must be ignore.because most of them are scam i mean real scam which i was a victim and i got ripped of thousands of dollars because i was so anxious to get my wife back after she left me for over 2 years with my 7 years old son jerry,i have applied to 7 different spell caster here and all to no avail they all ask for same thing send your name your ex name address and picture phone number etc which i did over and over again and most of them were from west Africa until i saw a post about mama Anita spell and i decided to gave her my last trail.she ask me four things my real name,my ex and my ex mother name and $180 and said my ex will come back in 24hours, i have paid over $3000 on spell casting and courier and nothing have work for me after 3 days i was thinking about how much i have lost so far so i said let me give her a try so i called her again and send my real name,my ex and my ex mother name and the $180 because i swear it was my last try so i was waiting as she told me to wait till next day and i could not sleep that night because i really love my wife and want her back at 9pm that day i saw my wife on line on face book and she said hi at first i was shock because she never talk with me for the past a year and 9 month now i did not reply again she said are you there? i quickly reply yes and she said can we see tomorrow i said yes and she went off-line i was confused i try to chat her again but she was no more on line i could not sleep that night as i was wondering what she is going to say, by 7.am the next morning she gave me a miss call i decided not to call back as i was still on shock again she call and i pick she said can we see after work today i said yes so she end the call immediately i got off work she call me and we meet and now we are back again i call mama anita the next day thanking her for what she has done in fact i still call her and thank her as my life was not complete without my wife please be careful here i have been scam thousands of dollars if you want a true love spell then contact mama Anita (mama.anitatruelovespell@gmail.com)685984565768

rm said...



My name is Sonia and I live in NY. i had problem with my ex boy friend some months ago. he was cheating on me which hurt me badly,and he was also avoiding me,He no longer picked up my calls.I was totally confused cos i didn’t know what to do. So i was surfing the internet for love spells to get him back and I saw Papa ogbefispell@gmail.com’s Youtube Video Testimonials. I knew I had to contact him and get him to help me. So i contacted t and she told me to order a consultation which I did. He told me everything, as if he had been there. The reading was simply amazing, I didn’t really believe in psychics, but after the reading, I knew psychics were real. And he told me that I needed some spells, so I did what I had to do to get them done by him. To cut it short.My ex boy friend gave me a call and said to me that we should have a date,i agreed.On the date,He was begging me to have him back and i agreed we are now together again,. Thank you Papa ogbefispell@gmail.com for rescuing my relationship…..continue your good work

leila stephaine said...


what will it take the whole world to know about dr.olubam who is the greatest spell caster in the whole world, there is nothing too hard for him to do, all his work his 100% sure and guarantee, just email him and pour out your heart desire on him and he will meet you according to your heart desire. i never believed on spell casting because many people most people from nigeria use this as a medium of making money by frauding us but all thanks go to dr.olubam and mrs kathrina from south africa for helping me also to get my ex-lover back. dr.olubam is the greatest amongst all and he is not a scam just beleive on his words and have faith on him and meet him according to his requirements and your heart desire will be granted. thanks and greetings from miss tina smith. the dr email is DR.OLUBAMSPELLHOME@GMAIL.COM AND DR.OLUBAMSPELLHOME@LIVE.COM