[00:00:01] Speaker 00:
case number 14-50-02.

[00:00:06] Speaker 00:
Wayne M. Anderson, appellant, versus Ashton B. Carter, secretary of defense at L. Mr. Light for the appellant, Mr. Williams for the appellee.

[00:00:16] Speaker 06:
Mr. Knight, good morning.

[00:00:17] Speaker 06:
Good morning.

[00:00:18] Speaker 06:
May it please the court?

[00:00:19] Speaker 06:
This case concerns the right of a reporter to seek judicial review of the termination of his embed status.

[00:00:27] Speaker 06:
The reporter, Mr. Anderson, seeks to proceed in this appeal under two theories, the Administrative Procedures Act and retaliation in violation of the First Amendment.

[00:00:37] Speaker 06:
With regard to the Administrative Procedures Act,

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The court needs to decide first whether there is an agency.

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And in order to do that, the court needs to determine whether the military authority exception applies.

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With regard to that exception, the legislative history demonstrates that Congress intended... When we look at the history, what does the exception say?

[00:01:02] Speaker 04:
What does the statute say?

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It says that military authority exercised in a battlefield in time of war is not reviewable.

[00:01:10] Speaker 06:
And then the question is, what is the meaning of that term, military authority?

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There has not been a lot of case law to decide that.

[00:01:18] Speaker 06:
You think that's a difficult question?

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I do think it's a difficult question.

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The court needs to take a functional approach to it.

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It's highly fact-specific.

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And in this case, in the Doe case, this court was indicted, but did suggest that the military authority exception applies only to relationships between a soldier and their superior.

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Looking at an analogous situation involving the Federal Tort Claim Act, the Supreme Court has observed that the policy behind such an exception is well served in order to prevent a situation where, for example, a soldier is challenging an order being given to him as negligent.

[00:02:08] Speaker 06:
But when a situation involves non-military personnel, you don't have that concern.

[00:02:15] Speaker 01:
So if I were to just ask, colloquially speaking, does the action you're complaining of constitute the exercise of military authority?

[00:02:22] Speaker 01:
Would you take the position that the answer to that could be no?

[00:02:25] Speaker 06:
It can be no, but it's a highly fact-specific.

[00:02:28] Speaker 01:
And how is it not the exercise of military authority?

[00:02:32] Speaker 06:
Well, the exercise of military authority, if it's read as this court read it in Doe, would involve only the relationship between a military superior and a soldier.

[00:02:47] Speaker 06:
I imagine it could be, in certain circumstances, also applicable.

[00:02:51] Speaker 01:
But there's nothing inherent about the terms exercise of military authority that say that it's only

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with regard to the relationship between a superior officer and a subordinate officer.

[00:03:03] Speaker 06:
That term itself is not defined, and it hasn't really been established in case law exactly what that term means.

[00:03:13] Speaker 06:
Which term?

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Excuse me?

[00:03:17] Speaker 06:
Which term?

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Military authority.

[00:03:20] Speaker 03:
What other authority would it be to remove him from his embedded status?

[00:03:25] Speaker 06:
Well, the issue here is simply interpreting something that's very much like a contract.

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The military authority was creating the media ground rules, making judgment-laden decisions about what the rules should be and what would happen to somebody that violated those rules.

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So the enforcement of the...

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The enforcement of it would be because it involves judgment.

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But the simple question of whether it was violated is something that courts are well equipped to determine, just like they determine contract disputes, whether a particular party violated the terms of a contract.

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That does not involve the kind of value judgments

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about and the exercise of a distinctly military function.

[00:04:14] Speaker 01:
So the APA includes a waiver of sovereign immunity?

[00:04:17] Speaker 06:
Yes.

[00:04:18] Speaker 01:
And is your understanding of the military authority provision that it sheds light on the scope of the waiver of sovereign immunity?

[00:04:25] Speaker 06:
Well, it defines what is meant by an agency, and obviously if there's not an agency, there's no claim under the Administrative Procedures Act, and so there would not be a waiver under the APA.

[00:04:39] Speaker 01:
So would we apply the canon in considering that we ordinarily consider waivers of sovereign immunity to be narrow?

[00:04:47] Speaker 06:
Well, I think that there's a powerful presumption in favor of judicial review, as this court observed in a case recently last year.

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And so you, I suppose, have competing canons in a sense.

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Have we applied that presumption of reviewability in the context of a waiver determination on sovereign immunity?

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I realize we use that language less, we use it about every year, but has it been applied in a relevant context?

[00:05:26] Speaker 06:
Well, I believe it's relevant in answering the question.

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For example, in the... Has it been applied in the context of defining sovereign units?

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I don't think it's been applied specifically to sovereign immunity, but the question that the court needs to answer here is to define the term military authority.

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In the context of determining whether or not there has been a waiver of sovereign immunity?

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In the context of determining what is an agency, which is both... And the reason we want to know that is

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I mean, you can do as many steps as you want to, but that's what we're trying to do.

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And you don't have a case, I don't think, where we have used the presumption of reviewability for that particular exercise.

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Well, obviously, if the APA does not apply, then its sovereign immunity provision does not apply.

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But the question of whether the APA applies, and therefore the attached sovereign immunity applies, involves the question of the scope of the act.

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That's what I think I was trying to get you to admit when I was asking you a question.

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The applied decanon of presuming review

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We're trying to find out whether that applies here, and I don't think we've ever applied that canon of presuming reusability in this context.

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I don't believe the Court's decided either way in this specific context.

[00:07:02] Speaker 04:
That would be consistent with what I suggested, I think, John.

[00:07:06] Speaker 01:
And just to understand the premise of your argument, so on the text of the military exception, you're focused exclusively on the phrase military authority.

[00:07:14] Speaker 01:
You don't take any issue with the notion that it was, insofar as the military authority, it was authority that was exercised in the field in a time of war.

[00:07:21] Speaker 06:
We don't take any issue with that.

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I would like to reserve the rest of my time for rebuttal, though the court doesn't have any further questions at this point.

[00:07:31] Speaker 06:
Thank you.

[00:07:32] Speaker 03:
All right, Mr. Williams.

[00:07:45] Speaker 02:
Good morning, may it please the court.

[00:07:48] Speaker 02:
I'm Wayne Williams on behalf of Federal Appellees.

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The decision of the district court should be affirmed for three reasons.

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The first reason is the district court construed the pro se complaint liberally to contain all of the legal theories based on the factual assertions presented in that complaint.

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After liberally construing the complaint, the district court applied the correct law, correct legal standard, and ultimately dismissed the complaint for failure to state a claim and for lack of jurisdiction.

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Indeed, the majority of the decision of the district court has not been presented here on appeal outside of the appeal of not granting a leave to amend.

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Instead, on appeal, there are newly raised legal theories.

[00:08:37] Speaker 01:
So you call them newly raised legal theories, but if you put aside the APA claim for a second and just talk about the First Amendment claim, you don't take issue with the notion that a First Amendment claim was raised in the complaint.

[00:08:49] Speaker 02:
Yes, I do not take offense to that.

[00:08:54] Speaker 01:
But the First Amendment... So then the question is, was the First Amendment, I think you think the question is, was the First Amendment retaliation claim raised?

[00:09:03] Speaker 01:
Correct.

[00:09:03] Speaker 01:
And I guess my question is, why does it have to be a First Amendment retaliation claim if somebody says, I was fired, I spoke, and then I was fired, that violated my First Amendment rights?

[00:09:14] Speaker 01:
Do they actually have to spell out that violated my First Amendment rights because it was retaliation for my exercise of First Amendment rights?

[00:09:23] Speaker 01:
Why can't they just say it violated my First Amendment rights?

[00:09:27] Speaker 02:
Your Honor, you have to put the defendant on notice as to your legal theory.

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And in this case, when you look at the balance of the complaint, it is clear that the constitutional right that the appellate believed had been violated was his constitutional right to be an embedded reporter.

[00:09:44] Speaker 01:
When you look at the- I don't think so.

[00:09:46] Speaker 01:
The first paragraph, one of the complaint, the very first paragraph of the complaint says, I'm seeking damages and injunctive relief.

[00:09:53] Speaker 01:
The damage has gone down.

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I'm seeking injunctive relief against defendants.

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acting under color law with the intent and purpose of depriving plaintiff of rights secured under the Constitution, First Amendment and Fifth Amendment by ruling adversely against plaintiff for his exercise of constitutionally protected speech, which means that what I'm complaining about is I exercised constitutionally protected speech and then I got an adverse result as a consequence of that.

[00:10:19] Speaker 01:
That sounds like it doesn't use the word retaliation.

[00:10:22] Speaker 01:
I'm not sure that it has to use the word retaliation.

[00:10:24] Speaker 01:
What it sounds like it's saying is, I spoke and then I suffered an adverse consequence.

[00:10:28] Speaker 01:
Ergo, my first amendment rights were violated.

[00:10:31] Speaker 02:
However, when you look at the balance of the complaint, you see that at paragraph 50, he states that the defendants caused the termination of the embedded status without due process.

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And also, at paragraph 50 of the complaint, at the time of his journalist embedded termination, plaintiff possessed a constitutionally protected interest that he was deprived of without due process.

[00:10:55] Speaker 01:
I don't see how those, first of all, I'm not sure that those are inconsistent with what's in paragraph one, but if you just look at paragraph one for a second and you bear in mind that this is a pro se plaintiff, if you just look at paragraph one, it's a pro se plaintiff who says this, what about that doesn't put somebody on notice that what I'm saying is I was fired or in this case I was invested in my embedded status because I exercised my First Amendment rights?

[00:11:18] Speaker 02:
I believe the district court also attempted to capture that in the footnote 10 of the district court opinion, where the district court did note that the plaintiff or the appellant had identified a former news embargo and that there had been antagonistic statements made to him.

[00:11:37] Speaker 02:
But he did not identify those individuals in the complaint, unlike the number of named defendants.

[00:11:43] Speaker 02:
And he never actually stated that because of the article that he wrote,

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his embedded termination status was removed.

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In fact, he always, and even in this court, wants to draw focus onto the video itself.

[00:11:57] Speaker 01:
I mean, these are sounding a lot like summary judgment arguments to me because they're pretty finely reticulated points about the exact parameters of his claim for purposes of the complaint, which is all we're talking about.

[00:12:08] Speaker 01:
I'm not even sure he has to do anything other than paragraph one and then add some facts.

[00:12:12] Speaker 01:
I spoke.

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Adverse action was taken against me before I spoke.

[00:12:17] Speaker 01:
Here's some of the ways in which I spoke, and he does spell that out.

[00:12:20] Speaker 01:
Yeah, there was a violation of my First Amendment rights.

[00:12:24] Speaker 01:
Even for a non-prosé plaintiff, that's stating a First Amendment claim, it seems to me.

[00:12:28] Speaker 01:
I'm not understanding how that's deficient.

[00:12:31] Speaker 02:
It seems to establish, when you look at the complaint, you look at his filings after being placed on notice by the defendants of the motion to dismiss that had construed the complaint to contain or to allege a First Amendment violation for removal of an embedded journalist position.

[00:12:50] Speaker 02:
And he just never comes back and states that, no, I'm not saying that my due process was violated because my embedded status was removed.

[00:12:59] Speaker 02:
He never takes that follow-on step and says, no, it's because of the words that were in the article that the army took or that the ISAF officials took comfort with.

[00:13:09] Speaker 01:
For his exercise of constitutionally protected speech, what is he talking about when he says, I suffered an adverse consequence for exercise of constitutionally protected speech?

[00:13:22] Speaker 02:
I do not know what was intended by that statement.

[00:13:26] Speaker 01:
And he does talk about the fact that he published an article in the complaint.

[00:13:30] Speaker 02:
He does, but he does not give any context of that article.

[00:13:34] Speaker 02:
It does not tie the decision of the military authorities that they actually removed him because of the article that he talks about in the video.

[00:13:44] Speaker 02:
However, moving past that, I mean, even if a First Amendment retaliation claim was reasonably raised by the complaint, the second thing that we have to look at is whether or not there is a corresponding waiver of sovereign immunity.

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And for a couple of reasons, there is not.

[00:14:01] Speaker 02:
The first reason is that this was a military coalition organized under the International Security Forces Afghanistan, which at the time fell under NATO command.

[00:14:13] Speaker 02:
The media ground rules, which he was found in violation of, was an actual ISAF agreement.

[00:14:20] Speaker 02:
And when he signed that agreement, he agreed, he noted that this was an ISAF agreement and that violation of this could result in the termination of his ISAF-embedded status.

[00:14:33] Speaker 01:
So for purposes of the APA claim, you're making the argument that this was an exercise of military authority in the field at a time of war?

[00:14:40] Speaker 02:
Absolutely, Your Honor.

[00:14:41] Speaker 01:
And I take it when you say exercise of military authority, you mean exercise of U.S.

[00:14:44] Speaker 01:
military authority?

[00:14:45] Speaker 02:
It was an exercise of military authority pursuant to ISAF.

[00:14:50] Speaker 02:
However, even if you were able to disaggregate the decisions of the military officials here, there would still be no waiver of sovereign immunity pursuant to the APA.

[00:15:01] Speaker 02:
As ISAF, the APA would not apply because ISAF is not a United States agency, but the military authority exception would apply if you were able to disaggregate the decision of the military authorities in this case as their United States military authority status.

[00:15:19] Speaker 01:
I'm not sure I fully follow that, but it sounds like at the end of the day, in order for the military authority exception to apply, you'd have to be talking about the exercise of U.S.

[00:15:26] Speaker 01:
military authority.

[00:15:27] Speaker 02:
For the exception to apply, yes.

[00:15:29] Speaker 05:
But don't for it to be needed, you would have to be talking about the U.S.

[00:15:33] Speaker 05:
If we're talking about the international aggregation of forces, then the waiver would not apply in the first place, because it wouldn't be an agency of the U.S.

[00:15:43] Speaker 05:
at all.

[00:15:44] Speaker 05:
Absolutely.

[00:15:44] Speaker 05:
Right.

[00:15:45] Speaker 05:
So it's only because

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We've got, if we get past that, within the time we need to decide what the military section looks like.

[00:15:53] Speaker 05:
That's correct, Your Honor.

[00:15:54] Speaker 01:
And you think it's clear from the, we can determine from the complaint.

[00:15:58] Speaker 01:
We don't have to know anything else and we can say that it's clear that we're not talking about, that we're outside sovereign immunity because we're talking about something other than U.S.

[00:16:07] Speaker 01:
authority.

[00:16:10] Speaker 02:
When you look at the complaint, he does mention that he was on a NATO base, and there are – he mentions the media grounds rules.

[00:16:19] Speaker 02:
The media grounds rules are an ISAF agreement.

[00:16:22] Speaker 01:
So – And the determination that divestment of embedded status is executed by?

[00:16:29] Speaker 01:
a U.S.

[00:16:29] Speaker 01:
military officer who signs it in their capacity as a U.S.

[00:16:33] Speaker 01:
military officer?

[00:16:34] Speaker 02:
In this case, they sign it in their capacity.

[00:16:37] Speaker 02:
The declaration provided by the defendant in the motion is dismissed.

[00:16:40] Speaker 02:
They sign their decisions as authorities under ISAF.

[00:16:45] Speaker 01:
Does the document actually say that?

[00:16:48] Speaker 02:
I'll check, Your Honor.

[00:16:59] Speaker 02:
It does not, Your Honor.

[00:17:01] Speaker 02:
Looking at joint appendix page.

[00:17:05] Speaker 02:
33, the decision by Colonel Bush, it does mention him as a colonel in the United States Army, chief of public affairs.

[00:17:12] Speaker 01:
It doesn't just mention him as that, that's the only way that he's reflecting his title, is as colonel of the U.S.

[00:17:18] Speaker 01:
Army, chief of public affairs.

[00:17:19] Speaker 02:
That is true, but if you look at the header of the memorandum, it's from the headquarters of the International Security Assistance Force, Joint Command, Kabul, Afghanistan.

[00:17:30] Speaker 01:
Sure, and he was definitely working there, I guess,

[00:17:33] Speaker 01:
It's hard to look at the order and think that he wasn't acting in his capacity as a colonel of the U.S.

[00:17:38] Speaker 01:
Army.

[00:17:40] Speaker 01:
And I'll just ask you one other point about sovereign immunity.

[00:17:41] Speaker 01:
So as I understand our decisions, the waiver of sovereign immunity that's in the APA, Section 702, it applies to any claim against a federal government officer seeking injunctive relief for their actions in their official capacity.

[00:17:55] Speaker 01:
It doesn't have to be an APA claim.

[00:17:57] Speaker 01:
Our decisions, I think, say that 702 is just an across-the-board waiver of sovereign immunity any time a plaintiff sees a federal officer for injunctive relief.

[00:18:06] Speaker 01:
Is that how you understand it as well?

[00:18:07] Speaker 02:
It does provide a broad waiver of sovereign immunity.

[00:18:10] Speaker 02:
However, 701 B1G, 702 still requires an agency action, which would then still bring us back to 701 B1G.

[00:18:22] Speaker 01:
For an APA claim.

[00:18:23] Speaker 01:
But I'm saying for the First Amendment retaliation claim,

[00:18:25] Speaker 01:
If someone just files a suit against a federal officer for violation of First Amendment rights, then the waiver of sovereign immunity with respect, and for seeking injunction relief, the waiver of sovereign immunity with respect to that claim comes from 702, even though it's not an APA claim.

[00:18:41] Speaker 02:
That is correct.

[00:18:42] Speaker 01:
OK.

[00:18:42] Speaker 02:
But 702 still defines that it applies to agency actions.

[00:18:48] Speaker 02:
So the exclusions of 701 would still apply to 702.

[00:18:51] Speaker 02:
702 wouldn't be completely unfair.

[00:18:54] Speaker 01:
Even in a non-APA claim?

[00:18:56] Speaker 01:
Even in a non-APA claim.

[00:18:57] Speaker 01:
It still has to be an agency defendant in order to fit with that's your argument.

[00:18:59] Speaker 01:
Okay.

[00:19:00] Speaker 02:
Yes, Your Honor.

[00:19:03] Speaker 02:
For the following reasons presented in our briefs, the decision of the District Court should be affirmed and the appeal should be rejected.

[00:19:12] Speaker 02:
Thank you.

[00:19:13] Speaker 03:
Thank you.

[00:19:14] Speaker 03:
How much time does Mr. Light have?

[00:19:17] Speaker ?:
Okay.

[00:19:22] Speaker 06:
I agree with your suggestion that some of these issues are best resolved on summary judgment.

[00:19:33] Speaker 06:
There is not a sufficiently developed factual record.

[00:19:37] Speaker 06:
In order for the appellees to raise the issue that the officers were acting in their NATO capacity, the evidence, the complaint itself doesn't present a lot of facts with regard to that and the attached exhibits.

[00:19:55] Speaker 06:
seemed to indicate that they were acting as US officials.

[00:20:00] Speaker 06:
And it's certainly, by analogy to the common law doctrine of borrowed servants, certainly possible for them to be acting in both capacities.

[00:20:08] Speaker 06:
I don't imagine the United States is going to argue that their official, that the United States had absolutely no control over their officials just because they were acting in their, they were detailed to NATO.

[00:20:25] Speaker 06:
And so I do think that what would be appropriate as a remedy here would be reversal of the decision to dismiss, and then the parties could proceed to some re-judgment, perhaps, after an opportunity for discovery on that issue.

[00:20:45] Speaker 06:
Uh, your honor, the parties haven't briefed the issue.

[00:20:49] Speaker 06:
And I'd be happy to provide some supplemental briefing on that.

[00:20:54] Speaker 05:
But I think that there is, um, uh, what would be doing at this point that would remedy any continuing harm to your client?

[00:21:07] Speaker 06:
It could provide declaratory relief.

[00:21:10] Speaker 05:
It could... Well, declaratory relief has got to have some kind of anchor.

[00:21:13] Speaker 05:
Right.

[00:21:14] Speaker 05:
I mean, we don't just, we don't give advisory opinions.

[00:21:18] Speaker 05:
That's right.

[00:21:18] Speaker 05:
And say, our court can't do that.

[00:21:21] Speaker 05:
Well, the declaratory judgment has to have some relief factor in the real world.

[00:21:26] Speaker 05:
Sure.

[00:21:27] Speaker 05:
And I'm not sure that I see what relief is left that we can do for your client here.

[00:21:33] Speaker 06:
Well, for example, he has suffered harm to his reputation by having a determination... You're not going for damages.

[00:21:40] Speaker 05:
No, not damages.

[00:21:41] Speaker 05:
You're not going for damages.

[00:21:42] Speaker 05:
Is there any injunctive or any equitable relief that would still be available in this case?

[00:21:49] Speaker 06:
Yeah, his reputation would be repaired through a declaration.

[00:22:00] Speaker 05:
property play with that question word i don't know if you're going to get married but the court didn't have one and it's not something of course you have to have a reputation for in order to make a claim in the archivist a bit just reputation enough and i need to be a prop is this case is there something still left here

[00:22:26] Speaker 06:
Right.

[00:22:27] Speaker 06:
Well, I mean, this isn't a question of due process.

[00:22:30] Speaker 05:
This is a question at this point of movement.

[00:22:32] Speaker 05:
And I want to know what relief it is, because the court can actually get it.

[00:22:37] Speaker 05:
You can't come to court and say, he called me something bad and he was lying.

[00:22:41] Speaker 05:
And I want you to say he was lying, unless you're also asking for judicial relief.

[00:22:46] Speaker 06:
Well, he's not just saying somebody's lying.

[00:22:48] Speaker 06:
He's alleging a constitutional violation.

[00:22:51] Speaker 06:
And the specific relief that would be granted for him would, for example, repair his reputation.

[00:23:02] Speaker 06:
But the question, I think, is- You think we can do this?

[00:23:06] Speaker 05:
Do you think that the judicial remedy that we can, that would provide standing or would survive a mootness?

[00:23:14] Speaker 05:
So I, the specific aspect of the mootness, I think you're asking about whether a decision from the court would- Is there anything less that a court can do that provides him judicial relief for a currently justiciable wrong?

[00:23:30] Speaker 06:
Yeah, I mean he would again be part of the embed program.

[00:23:33] Speaker 05:
Would he go back in the embed program?

[00:23:37] Speaker 06:
He would be eligible for it, and he would, you know, that would be... Has he even asked for that?

[00:23:48] Speaker 06:
There's nothing in the complaint one way or the other with regard to that.

[00:23:51] Speaker 06:
He hasn't asked for that, right?

[00:23:54] Speaker 06:
He wants his status restored.

[00:23:56] Speaker 06:
I don't know if he specifically wants to go back to Afghanistan.

[00:24:00] Speaker 01:
Are there still embedded reporters?

[00:24:02] Speaker 01:
That's just a factual question.

[00:24:04] Speaker 01:
I assume there are, or are there, do you know?

[00:24:07] Speaker 01:
In Afghanistan, are there still?

[00:24:08] Speaker 06:
In Afghanistan.

[00:24:09] Speaker 06:
There's nothing in the record one way or the other on that.

[00:24:13] Speaker 05:
Okay.

[00:24:15] Speaker 05:
Do you know?

[00:24:16] Speaker 05:
Do I know when we're slow knowledge?

[00:24:23] Speaker 06:
Do you know whether there are embedded reporters in Afghanistan?

[00:24:26] Speaker 06:
I don't personally know.

[00:24:27] Speaker 06:
Okay, thank you.

[00:24:29] Speaker 06:
Thank you.

[00:24:30] Speaker 06:
Thank you.