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Emily Berman

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New FBI Rules Go Too Far

Posted: 06/22/11 11:44 AM ET

Since 9/11, the FBI's power to investigate and collect information about Americans, often without any indication of wrongdoing, has expanded on several occasions. Now, according to the New York Times, the FBI is once again poised to extend its authorities by issuing a new version of the rules governing its domestic investigative activity. The changes represent another significant and troubling expansion of power, approved not by Congress or the Attorney General, but apparently by the Bureau itself.

Modifications to the FBI's rules governing agents' undisclosed participation in groups, such as religious congregations or political activists, are perhaps the most problematic. Current rules governing the FBI's monitoring of groups already cause serious concern because they are not even public, leaving us with no idea what constraints are in place or if they are sufficient. Now, the proposed changes allow FBI agents to attend five group meetings before those rules even apply. But what of the information gathered during those five sessions? Does a list of attendees make its way into a government database? Does a political activist opposed to U.S. policy find herself on a watchlist?

New rules regarding searching commercial or law enforcement databases also seem to invite abuse. They permit agents to search these databases without making any record of the search. Will an agent be able to resist the temptation of searching for information about neighbors, ex-girlfriends, or celebrities, knowing that he will not be asked to account for the search because no record of it exists?

Agents may also search an individual's trash for the purpose of finding material that might pressure him into becoming a government informant. Reports that federal agents use potential informants' immigration status or that of their family members for this purpose are already rampant. Now, agents will also be able to threaten a husband that they will show his discarded pornography to his wife, or threaten to bring criminal charges against someone whose trash contains traces of marijuana.

The FBI should of course have the power to follow every lead. But agents can do that without using the highly intrusive tools permitted by the current rules, much less the even-more-liberal impending rules -- this is not an all or nothing issue.

An agent can respond to a tip about a suspicious-looking car with no license plate by going to look at the car to determine if it poses a threat -- such as whether it contains some sort of explosive device. The current regulations, however, would allow that agent to look at the car; follow its driver 24-hours per day documenting all of his activities; interview his neighbors under the pretext of being someone else; and send an informant into his place of worship to find out what his rabbi, priest, or imam preaches. And the new rules add to that list the ability to go through the driver's friends', coworkers', or neighbors' garbage, looking for leverage to use to get them to spy on him.

These most recent changes also raise what is perhaps a broader, more systemic concern: One can infer from the New York Times article's statement that the FBI "does not need permission to alter its manual" that the FBI itself took the lead in formulating these new rules. This is problematic.

The very purpose of this set of rules is to ensure that the FBI's investigative activities are limited in scope, never more intrusive than necessary, and subject to proper oversight. They safeguard Americans' civil liberties against law enforcement activities that, absent sufficient regulation, could result in unwarranted intrusions into people's lives. But even the most well-intentioned FBI officials are likely to craft rules that err on the side of permitting agents to act aggressively. Thus the fox is not only guarding the henhouse -- he is also determining how high the fence that surrounds it and how thick the walls will be.

A continuing trend -- one that started years ago but accelerated rapidly after 9/11 -- is to increase federal law enforcement power while cutting back oversight of how that power is used. This trend has eliminated many of the measures implemented to avoid the now notorious Hoover-era abuses resulting from the consolidation of too much power within a domestic intelligence agency. In light of these many recent changes, it is time that Congress and the American people take a closer look at the FBI's investigative powers, consider whether they may have grown too broad, and act to re-establish meaningful limits on the ways the Bureau carries out its mission.

 
Since 9/11, the FBI's power to investigate and collect information about Americans, often without any indication of wrongdoing, has expanded on several occasions. Now, according to the New York Times,...
Since 9/11, the FBI's power to investigate and collect information about Americans, often without any indication of wrongdoing, has expanded on several occasions. Now, according to the New York Times,...
 
 
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09:37 AM on 06/23/2011
Cop killings are up by 41%. I think it will continue to rise.
HUFFPOST SUPER USER
dbrett480
03:17 PM on 06/25/2011
They probably will, but this has nothing to do with it.
08:28 AM on 06/23/2011
This article is nothing more than paranoid speculation. Ms. Berman fails to cite any law or Constitutional protection that will be changed by these rules. Nor could she because there are none. To wit:

Law enforcement officials have for a long time had the right to do a warrantless search of your garbage left outside the curtilage (only lawyers can talk this way) of your home (see California v. Greenwood). Likewise an officer-without a warrant- can go undercover in an organization. In both cases the citizen has no expectation of privacy-the standard needed for a 4th Amendment violation.

Ms. Berman's argument essentially boils down to what "might" happen under the new rules. Putting aside the fact that this is pure speculation even her hypotheticals are weak. For example, she speculates that an agent might threaten a man with disclosure to his wife of discarded pornography. Putting aside whether such sensitive information should be discarded this way (i.e. the neighbor, the kids, etc. could also find it and threaten to disclose it) the agent in Ms. Berman's hypothetical is probably committing an existing crime (e.g. extortion) depending on what he is requiring the man to do to avoid disclosure. Of course discovery of a small amount of drugs could lead to a "legal threat" e.g. disclose your supplier or we'll charge you with a crime. But an example like that undermines her argument because additional safeguards in that example would only benefit the guilty not the innocent.
09:46 AM on 06/23/2011
I wonder if a person's First Amendment right of association is violated when they join groups or associations that have been infiltrated by law enforcement officers that have joined under false pretenses to obtain the names of the group's members? It seems like such under-handed tactics would have a chilling affect on folks interested in joining groups of like-minded people. Of course, legitimate law enforcement actions based on sound intelligence and following the issuance of a warrant by a neutral decision-maker would be fine, but to let law enforcement officers infiltrate groups without probable cause or reasonable suspicion of wrongdoing is an open invitation for abuse by a group of people that have proven time and time again they can't be trusted with increased power.
10:49 AM on 06/25/2011
You actually raise an interesting point (as opposed to the usuaul name callers) However, again without a specific act of a rights violation the answer will usually be no. The reasons are:

1) If you're claiming a 4th Amendment violation you have to show that you had a reasonable expectation of privacy that was violated. That's in part why police can put security cameras on the street with no violation- there is no privacy explanation on what you hold out to the public. Likewise in formal groups (whether they are actually called public is irrelevant)-what you say and do is not expected to remain private.

2) Conceivably you could eventually get a 1st Amendment case. The problem here is that you must show a concrete and particularized injury (otherwise the Court will dismiss for lack of standing-they won't look at abstract cases), i.e. you can't just claim it had some broad chilling effect on speech. Most of the time law enforcement is doing just the opposite- they keep a low profile hoping you'll continue speeking, texting, etc. so as to get evidence. However, if you have a specific set of facts (even hypothetical) I'd love to look at it
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Mary Blickhahn
Mary Quite Contrary
10:19 AM on 06/23/2011
Yes but we are constantly seeing evidence of police and federal agents being allowed to freely interpret a law and take it to an extreme level it was not intended. This makes her concern a real one. Assuming the FBI wouldn't go to any extreme doesn't fix the problem that is actually at hand. You also fail to realize there are a lot of examples of just how abusive and over reaching the FBI can get.
07:13 AM on 06/23/2011
Sorry gang, but you all are late to the party, the FBI has been engaging in these very same activities since the 1950's when the USA was in the midst of the "Red Scare," the program was called, COINTEL PRO. The program was allegedly disbanded in the 70's, but who in their right mind believes that? COINTEL was used to track, imprison or even kill US citizens the agency deemed as threats to national security. Now the program has morphed into "targeting individuals", and yes, they get your neighbors, your employer, even your pastor to spy on you if you become a targeted individual. Local law enforcement works hand-in-glove with the FBI in implementing a institutionalized program of spying and harassment of individuals that express their own opinions and don't tow the corporate line. Why do you think the country is moving towards privatized security forces, because they don't have to follow the Constitution, they're private--the Constitution protects us from government overreach, not private conduct---you would have to link the private contractors actions to government control before you could hold a contractor legally liable for violating your rights. Yea, the takeover is right in front of our faces, it's all about rich white men retaining power once the white majority in the US is no more. Can you say, American Apartheid? Coming to a country near you.
06:48 AM on 06/23/2011
This is what fear allows to happen.
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pflickner
Democratic Candidate for AZ State House
01:37 AM on 06/23/2011
Anonymous and LulzSec, you guys reading this?
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ABACADABRA RABBIT
VOTE GREEN PARTY 2012
01:57 AM on 06/23/2011
reading what?
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01:00 AM on 06/23/2011
Self-regulation always works .... yes?
10:32 PM on 06/22/2011
Can Emily Berman be specific with the alleged unconstitutionality of the FBI's new rules? If she cannot, then her criticisms of them are merely cosmetic, and do not represent a significant infringment on rights.
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onionboy
Blessed are the Cheese Makers
12:53 AM on 06/23/2011
I think everyone understands that it's the 4th amendment she's talking about.
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pflickner
Democratic Candidate for AZ State House
01:38 AM on 06/23/2011
Obviously, you don't believe in reading the citations she posted - you know, the links? I guess that takes too much more effort than stating your unsubstantiated opinion.
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Mary Blickhahn
Mary Quite Contrary
10:27 AM on 06/23/2011
In fairness you make a good point. However the author's point is still real. McCarthyism was a terrible chapter in US history and could easily be repeated. Nosy and troublesome neighbors already report bogus claims of child abuse, welfare fraud, and anything else they think they can. Calls to code enforcement and HOA's for every little thing because they have nothing better to do. The foundation for this type of paranoia does actually exist, weather you think so or not.
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undertheinfluence
POW in my own home country
10:25 PM on 06/22/2011
The art of fear is at work, very few comments here is proof of that. Who will be the next target of some who knows for what surveilence mission.

By the way, who is protecting us from those who protect us?
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undertheinfluence
POW in my own home country
05:44 PM on 06/22/2011
Can you say..Orwellian Police State?
04:51 PM on 06/22/2011
In a police state it is bad form to criticize the police or question their motives. You better leave the country.
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OleProfessor
"Ours is not a system based upon trust"
04:05 PM on 06/22/2011
The FBI never fails to overstep it's bounds, abuse it's authority given, or alienate the American Public often when it needs it's confidence and cooperation the most...

This is a matter of record...
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BlackBuddha
I didn't mean to, I meant to
02:59 PM on 06/22/2011
Hopefully, agents dedicated to the Constitution will become the FBI's version of Bradley Manning.
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ruleoflaw66
And I'd opt out of 'fans' too if I could.
01:37 PM on 06/22/2011
The real tragedy is that this is happening with the tacit approval of the prez. His record on rights abuses is abysmal.

http://www.guardian.co.uk/commentisfree/cifamerica/2011/jun/14/rescind-barack-obama-obama-transparency-award
04:27 PM on 06/22/2011
Looks like I have already fanned you!
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dkrypt
Unencumbered by political correctness
01:02 PM on 06/22/2011
Law enforcement is way out of hand.

Please elect a real American who'll rein them in. Hard.
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OliverTwist
Contrarian advocate for truth and justice
10:07 PM on 06/22/2011
Dennis Kucinich.