Status of the ATI -vs- Mann and UVa emails saga

AMERICAN TRADITION INSTITUTE – PRESS RELEASE July 26, 2012

The ongoing saga of the American Tradition Institute versus the University of Virginia moved forward this week with filing of the arguments of the parties http://www.atinstitute.org/law-ctr/hosted-foia-documents/ on the central issues of the case. The legal arguments are shaping up to be all about academic freedom and less about whether the University can exempt the Michael Mann emails.

Under its primary argument under the Freedom of Information Act, the only emails the University can withhold are those that were produced or collected in the conduct of or as a result of study or research where such data records or information has not been publicly released, published, copyrighted or patented. A careful examination of the 31 emails placed before the court as “exemplars” of the 12,000 emails show that all but two of them reference research in some manner and of these 25 actually contain data, records or information produced or collected in the conduct of study or research.

Comparing those emails against Mann’s professional papers, ATI found that in every case, the data or information had long been released through publication. Facing this situation, the University has only one refuge – to claim academic freedom. Their argument is quite simple and quite wrong. They argue that release of the emails would chill academic discussions and those discussions are protected speech under the first amendment. They are joined in this argument by Michael Mann and in a separate amicus brief filed by the American Association of University Professors.

Here is the central question the court will face – does the First Amendment right to free speech in a public forum trump the right of citizens to see communications made by a public employee conducting government business. Because all but possibly one ambiguous email was made by a public employee in the conduct of public business, the First Amendment is not applicable. This is old, settled law: See, United States v. National Treasury Employees Union, 513 U.S. 454, 465 (1995) (speech on an issue unrelated to the speaker’s employment duties is protected speech, but where the speech is by an employee in his capacity as an employee on an issue involving their duties, the speech does not meet the Pickering threshold test.); and, Holland v. Rimmer, 25 F.3d 1251, 1254-55 & n.11 (4th Cir. 1994).

Lead Counsel for ATI, David Schnare, explained, “There have been few careful analyses of the Constitutional protections of Academic Freedom. Where the court has looked carefully, the First Amendment has never been found to offer any protection greater than that afforded any citizen.” He continued, “This case will tear down much of the opaque mystic university faculty have raised around their activities. It will give citizens the opportunity to monitor their university employees, something clearly needed in the climate debate.”

The ATI brief raises many more arguments showing why the University has no First Amendment rights under the banner of academic freedom. The Court will hear the parties arguments in a hearing on September 17th.

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July 26, 2012 11:27 am

[trimmed by author’s request]

July 26, 2012 11:35 am

Sorry for posting in the wrong thread. Reposted in the Greenland ice.

Skiphil
July 26, 2012 11:43 am

Interesting to see them struggling to come up with a new rationale….
1st Amendment to the US Constitution:
“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.”
The actual 1st Amendment applies solely to what the US CONGRESS may and may not do. Then since the “Gitlow” case courts have extended it to apply to states. However, there is no plausibility at all to claiming that the 1st Amendment describes academic freedom. Even taking UVa as a “state” institution the emails issue and FOI don’t relate to “abridging the freedom of speech” and the AAUP is about private as well as public universities (so whatever doctrine of academic freedom they promulgate is not about a special status for employees of public institutions). It’s simply not an academic freedom issue.

July 26, 2012 11:48 am

For a Mann who has nothing to hide …………………..

July 26, 2012 11:52 am

War is Peace. Freedom is Slavery. And Freedom of Speech allows you to keep something secret.
The issue seems pretty simple to me: I have a right to see anything produced by UVA, because as a Virginia taxpayer, I damn well paid for it. If you want your work to be private, fine: but don’t insist on being paid with public funds.

mpaul
July 26, 2012 11:57 am

If the judge were to rule that academics have a first amendment right to keep their official communications private, then that ruling would effectively gut all of the sunshine laws. First, why would we consider academics to be a special class apart from other public employees? I know that climate scientists they often consider themselves to be special — in the same way that the Blues Brothers claimed to be special because they were on “a mission from god”. But in reality, they are not. We don’t have special aristocratic classes in the American system — that’s what the revolution was partly about. Second, every public employee could then claim a first amendment right to keep their official communications out of the public eye. City councils could claim this right as justification for back room dealing. EPA employees could claim this right to prevent the public from knowing the technical basis for regulations. Where would it stop?
I think UVA has a weak hand, but I suspect the real game here is to simply drag this out for as long as possible.

RACookPE1978
Editor
July 26, 2012 11:59 am

But, you see, the “liberals” don’t want Steyn (or other conservatives) or other writers such as M&M to have “free speech” ABOUT public policy …
They want to claim that “free speech” is ONLY allowed for the emails (written at work on public computers about public research in publicly-paid offices using publicly-paid servers) about “paid speech” that UVA or Penn State or NASA-GISS can claim based on the “speech” ABOUT money received for public research affecting trillions in public policy tax money worldwide and public policy towards energy and commerce affecting billions of innocents worldwide.
/sarchasm – That gaping whole between a liberal and the real world 8<)

zefal
July 26, 2012 12:01 pm

It will chill academic debate malfeasance.
These emails were taken out of context!
Just warming up the old refrain to keep it in prime running condition for when needed.

Ray
July 26, 2012 12:07 pm

At the end of the day they might need to plead the 5th…

tadchem
July 26, 2012 12:08 pm

You would think that Nixon’s former secretary Rose Mary Woods (of the “18-minute gap in the Nixon Watergate Tapes” fame) has a grandchild working at UVa.

Paul Westhaver
July 26, 2012 12:23 pm

Piltdown Mann… another science fraud. Looks like UVA is getting ethics guidance from Penn State. That long thick track of slime associated with this guy has the bottom feeding lawyers torturing “transparency” into bunker mentality.

Fred
July 26, 2012 12:26 pm

Time for a new label to counter their AGW.
I propose MCF . . Mannian Climate Fearmongering.
Must be some other good ones . . .

Coach Springer
July 26, 2012 12:31 pm

ATI is going to need more money. UVA will go all the way to the Supreme Court to avoid it or ATI will have to to get it. And it will still depend on a muddy 5-4 decision. Since Roberts seems to want an express enumeration of protections and academic freedom is not expressly enumerated, it might go ATI’s way, but predicting that is going way out on a limb.

more soylent green!
July 26, 2012 12:41 pm

Academic freedom is just another one of those phrases they trout out when they don’t want to be held accountable. As individuals, they have no more or less freedom than anyone else and as public employees, they’re official communications are public property, except in very few cases.

July 26, 2012 12:41 pm

Check out Manns mails in the filing.

Gail Combs
July 26, 2012 12:49 pm

I keep thinking of the courts decision on the Nixon tapes. The President, claiming executive privilege, filed a motion to quash the subpoena.
This is from the Full Text of the Supreme Court Decision In The Watergate Case.

4. Neither the doctrine of separation of powers nor the generalized need for confidentiality of high-level communications, without more, can sustain an absolute, unqualified Presidential privilege of immunity from judicial process under all circumstances. See, e. g., Marbury v. Madison, 1 Cranch 137, 177; Baker v. Carr, 369 U.S. 186, 211 . Absent a claim of need to protect military, diplomatic, or sensitive national security secrets, the confidentiality of [418 U.S. 683, 685] Presidential communications is not significantly diminished by producing material for a criminal trial under the protected conditions of in camera inspection, and any absolute executive privilege under Art. II of the Constitution would plainly conflict with the function of the courts under the Constitution. Pp. 703-707….
7. Since a President’s communications encompass a vastly wider range of sensitive material than would be true of an ordinary individual, the public interest requires that Presidential confidentiality be afforded the greatest protection consistent with the fair administration of justice, and the District Court has a heavy responsibility to ensure that material involving Presidential conversations irrelevant to or inadmissible in the criminal prosecution be accorded the high degree of respect due a President and that such material be returned under seal to its lawful custodian. Until released to the Special Prosecutor no in camera material is to be released to anyone. Pp. 714-716.

Seems Mann and U of VA seem to think they have special privileges that the court did not see fit to grant a sitting president of the USA.

July 26, 2012 12:50 pm

Modern courts have a tendency to ignore the original intent of the First Amendment free speech guarantee: that citizens may criticize the government, its policies and officials, and assemble with others to discuss what the government is doing and organize peaceful opposition (or support) of those policies and officials.
In this context, interpreting the First Amendment to prevent citizens from leaning what their government is doing (indirectly, through funding of research) and thereby forstall potential criticism and opposition is an absolute perversion (but not, alas, unthinkable for modern courts). The FOI legislation formalizes the presumption that if it is public business, or carried out with public funding, then the public has a right to know what was said and done.

Patrick
July 26, 2012 12:54 pm

“Academic Freedom” has no basis in law. It is simply an ideal, not a law, created by universities and professors. Usually trotted out to support some university’s or professor’s position and never with concomitant responsibilities – like many liberal social programs.

July 26, 2012 12:57 pm

Often I’ve read CAGW defenders describing FOI request as harassment, distracting etc.
But in this case, everything is already buddled.
Just turn it over. End of harassment. End of distraction. … Assuming what’s in them shows Mann was on the up and up.

Luther Bl't
July 26, 2012 1:04 pm

A most interesting legal argument. Perhaps it is time for the public to find out what really happens when academics are free “to think the unthinkable”, and the monstrous immorality of some conceptions nourished with care before being allowed out to rampage on the street.

July 26, 2012 1:04 pm

“Time for a new label to counter their AGW.
I propose MCF . . Mannian Climate Fearmongering.
Must be some other good ones . . .” – Fred
They already have an acronym for it, it’s “BS”. I’ll leave it to you to figure out what that means, I’m sure you’ve heard it before.

KnR
July 26, 2012 1:11 pm

‘to claim academic freedom’ and the legal validity of ‘academic freedom ‘ is what .
This a a question of the law not the nicety of academia, and if were lucky UVa will fail to realise that and think all they need is usual ivory tower approach of a few quite word and some back stroking to make the problem go away .

Gail Combs
July 26, 2012 1:16 pm

The other point is the The “open fields” doctrine and the expectation of privacy issue.
Even a locked gate with a “No Trespassing” sign did not give rise to the expectation of privacy in this court decision

… He had posted “No Trespassing” signs at regular intervals and had locked the gate at the entrance to the center of the farm. App. to Pet. for Cert. in No. 82-15, [p174] pp. 23-24. Further, the court noted that the field itself is highly secluded: it is bounded on all sides by woods, fences, and embankments, and cannot be seen from any point of public access. The court concluded that this was not an “open” field that invited casual intrusion….
The court concluded that Katz, upon which the District Court relied, had not impaired the vitality of the open fields doctrine of Hester. Rather, the open fields doctrine was entirely compatible with Katz’ emphasis on privacy. The court reasoned that the “human relations that create the need for privacy do not ordinarily take place” in open fields, and that the property owner’s common law right to exclude trespassers is insufficiently linked to privacy to warrant the Fourth Amendment’s protection.

There is also the Cell Phone warrantless search controversy that is going on right now. “…courts have reached conflicting opinions on whether a search warrant is necessary for cell phone location tracking records that are held by wireless company providers…”
As far as e-mails sent in the work place goes.

….In finding that Aguiar had no reasonable expectation of privacy, the court adopted the four factors used In re Asia Global Crossing, Ltd., 322 B.R. 247, 257 (S.D.N.Y. 2005) to determine whether an employee has an expectation of privacy in emails generated at the workplace. The factors consider whether:

(1) the company maintains a policy banning personal or other objectionable use, (2) the company monitors the use of the employee’s computer or email, (3) third parties have a right of access to the computer or emails, and (4) the company notifies its employees, or was the employee aware, of the company’s use and monitoring policies.

Here, these factors were easily satisfied by the employer’s generic information technology policy stated in its employee handbook that it sufficiently promulgated. As long as an employer adheres to its own established policy, its employees have no expectation of privacy in emails transmitted through the employer’s server. The court noted that “sending a message over [an] e-mail system was like placing a copy of that message in the company files.” The court may have gone farther than its holding citing Black v. State, which found attorney-client privilege inapplicable for a telephone call when the party was warned that telephone conversations were monitored and taped….
http://ellblog.com/?p=1919

It would seem that the employee/student handbook may be a key factor in the case.

BarryW
July 26, 2012 1:21 pm

Insane logic. How does The right to say something allow it to be hidden from the rest of us? Add to that the use of public resources. As a tax payer I have a right to the product of my employees (government workers) work. Their argument is nothing but elitist crap and it sickens me that the VA legislature doesn’t just drop on them like a ton of bricks and put them in their places. This should never have had to go to court. They’ve wasted the taxpayers money defending the indefensible.

JohnH
July 26, 2012 1:31 pm

Steven Mosher says:
July 26, 2012 at 12:41 pm
Check out Manns mails in the filing.
I did, lots of mentions of a Frank Very or a Very Frank but never heard of him 😉

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