Branson Mayfield, a lawyer in Oregon was arrested by the Federal bureau of Investigation (FBI) in May 2004 as a suspect when terrorists attacked several passenger trains in Madrid, Spain in March 11, 2004. These attacks left over 190 passengers dead and over 1500 injured (Martin 1). Mayfield was suspected to have participated in the attack because the FBI lab had matched his finger prints to those found on a bag that contained the explosives in the Madrid attack. Mayfield was taken into custody but two weeks later, the Spanish National Police (SNP) notified the FBI that it had also matched the fingerprints found on the bag with those of an Algerian citizen. Later, the FBI lab established that indeed, the fingerprints on the Madrid bag perfectly matched those of the Algerian. Mayfield was immediately released from the custody. Therefore, this paper will elucidate events leading to Mayfield arrest and the subsequent implication of this event in the legal profession (US Department of Justice 1).
Description of Forensic Laboratory investigation
When the SNP recovered some fingerprints on the bag that contained detonators, they were relayed to the FBI lab for further analysis. The FBI’s Latent Print Units (LPU) later established a positive match between the fingerprints on the bag and those of Mayfield described as Latent Fingerprint Number 17 (LFP 17). His fingerprints, along with others, had been identified as probable match to LFP 17 when the FBI ran a search for the fingerprints using the Integrated Automated Fingerprint Identification System (IAFIS) through its database. From millions of fingerprints contained in the FBI Criminal Master File, the IAFIS system produced a list of 20 fingerprints that came close to matching the LPF 17. On March 17th, 2004, Agent Green, an FBI fingerprint expert established that Mayfield’s print matched the LFP 17. The same decision was confirmed by Massey, a former FBI agent. The fingerprints were then sent to Wieners, a senior FBI manager who also verified the result (Giannelli 61).
Following this finding, the FBI launched a thorough investigation of Mayfield. He was placed on a round-the-clock surveillance. The Bureau found out that Mayfield was a lawyer in Portland, Oregon. The Bureau also discovered that Mayfield was a Muslim married to an Egyptian migrant. The FBI learned that Mayfield was in contact with a number of individuals suspected to be engaged in terrorism activities. Nonetheless, the FBI was unable to gather any data that expressly connected Mayfield to the terrorist attacks on the passenger trains in Madrid. In order to intensify its investigation, the FBI acquired permission to carry out physical searches and clandestine electronic surveillance of Mayfield according to the Foreign Intelligence Surveillance Act of 1978 (FISA). The Bureau searched his home and confiscated computer hard drives from his office. Also the FBI analyzed Mayfield’s personal financial records, his clients, online sites visited and private talks between him and his wife and between parents and children (US Department of Justice 2). His family was not told where he was being detained. The FBI however informed them that he was suspected to have participated in the Madrid terrorist attacks, a crime punishable by death (Martin 6). On May 17th, the court selected an independent expert to reassess how the FBI settled on Mayday’s prints. Two days later, the expert arrived at a similar conclusion. Nevertheless, on May 19th, the FBI was notified by the SNP that it had conclusively spotted LFP 17 as the prints of Ouhnane Daoud, an Algerian citizen. After the FBI lab evaluated Daoud’s fingerprints, Mayfield was set free by the court (US Department of Justice 3).
Professional practices findings from the case
The FBI initially offered a number of clarifications for the fingerprint mishap. Some of the reasons included: inaccessibility to the original prints on the bag; low quality of the digital photo of LFP 17; and the resemblance between Mayfield’s prints and the LFP 17. The FBI later set up a two-day meeting with a panel of international fingerprint specialist to ascertain the failures of LFP 17 and recommend improvements in the FBI fingerprint analysis. A number of specialist in the panel observed that the initial FBI expert that analyzed Mayfield’s print did not carry out a comprehensive study of LFP 17 before performing the IAFIS search, which later made him to ignore vital disparities between Mayfield’s fingerprints and the LFP 17. Some panelists mentioned overreliance in the ability of IAFIS and the anxiety of working on high-status case as a contributory factor to the blunder (US Department of Justice 3). The panelists concurred that the subsequent verification procedure was influenced by the outcome of the initial assessment (Giannelli 61). A number of suggestions were made by the panelists to prevent the recurrence of a similar incident. Enhanced documentation process and an improved verification process were also proposed. The FBI later issued an official report that identified the LFP 17 as belonging to Daoud (US Department of Justice 4).
Impact on legal proceedings
Following this event, Mayfield sued the DOJ, FBI and a number of individuals for violating his constitutional civil rights and privacy (Aiken 1026). Mayfield claimed that he was illegally arrested and imprisoned by the FBI (kneedler et al 3). The claims also included illegal search, seizer and surveillance of his residential house and office, an act that violated his constitution rights as enshrined under the Privacy Act V (Amicus Attorney 10). On November 29th, 2006, Mayfield and the government reached an agreement, one that was ratified by the district court. The deal entailed the following provisions: Mayfield would be paid two million dollars as a compensation for damages; all information gathered via electronic surveillance would be destroyed; all properties seized from his office and residential house to be returned; and a formal apology to be issued to Mayfield (Amicus Attorney 10; Associated Press 8). In return, Mayfield accepted to absolve the government of all charges except those related to electronic surveillance of his office and residence, and the physical seizer of his possessions. Mayfield and the government also signed a Recitation of Stipulated Facts a pact that would guide any future legal actions against the state (Amicus Attorney 11).
Mayfield later filed a suit-before Richard A. Paez and Johnnie B. Rawlinson, the US District Judges for the District of Arizona-challenging the legality of the amendments by the PATRIOTIC Act that allowed FISA to conduct physical searches and electronic surveillance on his residential and office premises without a valid reason. Mayfield stated that the statutory amendments were illegal. He asserted that the FBI’s decision not to annihilate all materials seized from his premises prolonged his anguish. Mayfield feared that this material evidence would be used to victimize his family in the future (Amicus Attorney 12). The government countered this claims on two fronts: one, that Mayfield did not have legal mandate to question the Fourth Amendment claim; and two, the court did not have authority over the matter. However, the court ruled that it had jurisdiction over the matter, which it could rectify via a declaratory ruling. As regards to the amendments by the PATRIOTIC Act on 50 U.S.C. 1804 and 1823, the district court ruled that these adjustments were illegal since they contravened the conditions of the Fourth Amendment of probable cause and because they permitted FISA’s actions on the basis of an important purpose rather than the prime purpose (kneedler et al 2).
Mayfield’s decision to seek a declaratory judgment was based on two hypotheses: one, to avert future use of any derivative materials by FISA against him; and two, to compel the FBI to annihilate all material evidence seized from him illegally. However, the court of appeals overturned the ruling made by the district court. It stated that Mayfield did not have Article III status needed to sustain his claim (Russell 1). The courts of appeal however agreed with the district court that the FBI’s possession of the derivative materials seized contravened Article III (kneedler et al 2).
The appellate court also ruled that a declaratory ruling about the legality of the PATRIOTIC Act amendment of 50 U.S.C 1804 and 1823- the only available reprieve to Mayfield with regard to the terms of settlement between the government and Mayfield- would not remedy that injury (kneedler et al 6). Mayfield could not pursue his claim on the Fourth Amendment since his grievances had already been considerably leveled out via the settlement. As a result, the declaratory verdict would not affect him or his family. Thus, the government was not under any legal commitment to annihilate or turn over all the material evidences seized by the FBI from Mayfield’s premises because his claims did not meet the legal threshold required to revitalize Article III (kneedler et al 7).
The ruling by the court of appeal that Mayfield did not have Article III status is correct and in no way does it conflict with any ruling of the district court (Paez & Rawlinson 7). Several arguments emerge from this ruling: one, a petitioner must ascertain his Article III status to file a suit by carrying the burden of proof that he has experienced a real and specific injury. He must prove the existence of a causal relationship between his conduct and the injury. He must also show that the probable injury will be rectified by his demand for relief. In view of the latter prong of this inquest, it must be probable, rather than simply tentative that the injury will be rectified by a positive ruling. In addition, since status is not allotted in gross, a petitioner must express status discretely for every type of relief required (kneedler et al 8).
This law has a meticulous salience when a petitioner who has experienced an injury before requests probable relief for instance, a declaratory ruling. The existence of a previous injury can bestow status to ask for financial damages but it does not imply that the petitioner will thus possess status to seek probable relief too. In Mayfield’s case, the appellate court was right when it ruled that the plaintiff did not ascertain that his supposed injury would be rectified by a declaratory ruling. In his settlement deal with the government, Mayfield liberated all claims apart from his challenge to the legality of the Fourth Amendment (50 U.S.A. 1804 & 1823) (Forkey 16). As a result, Mayfield threw away his right to any form of relief except a declaratory ruling relating to the facial constitutionality of those amendments. The district court was thus not in position to issue a ruling obliging the US government to return or obliterate the derivative materials held by FISA. The court (district) could also not make a declaratory ruling about the retention of derivative materials by the government (kneedler et al 8). The only viable remedy accessible was the ruling that the Fourth Amendment was illegal.
The district court presumed that if it ruled that the significant purpose merit of 50 U.S.C 1840 and 1823 to be facially illegal, the government would be compelled to strip itself of the material evidence held by FISA so as to obey the court ruling. However, as elucidated by the court of appeal, this hypothesis is not valid. The court of appeal has already set precedence, outside the confines of criminal cases, which the government is usually allowed to make use of material evidence it acquired through illegal search (Aiken 42). As such, even if the legal amendments relevant to Mayfield’s case supposedly violated the Fourth Amendment, the state could still hold on to the material evidence and would not be compelled to obliterate them so as to- according to the district court- act constitutionally (kneedler et al 10).
The argument is not that the US government was not keen to respect the conditions of the declaratory ruling required by the Mayfield or that he did not have status since the district court does not have authority to coerce conformity with such ruling. The appellate did not grasp, and the state has not disputed in this case, that Article III injury normally can’t be rectified by a declaratory ruling except injunction relief is accessible to put into effect the ruling. The important point is that conformity with the ruling merely will not rectify the plaintiff’s injury since it is lawful for the state to hold on to and utilize derivative materials acquired via illegal means. As a result, the court of appeal determined that it was not probable rather than simply tentative that Mayfield’s (the plaintiff) injury will be rectified by a declaration ruling, and as a result, the plaintiff does not have a status to invoke Article III in his claim (kneedler et al 10).
Works Cited
Aiken, Ann. Opinion and Order. 2007. Web.
Aiken, Ann. Mayfield v. US. 2007. Web.
Amicus Attorney. United States Court of Appeals, Ninth Circuit. Web. 2011.
Associated Press. FBI Apologizes to lawyer held in Madrid bombings. AP. 2004. Web.
Forkey, Russell. Mayfield v.US, 07-35865. 2009. Web.
Giannelli, Paul. “Confirmation Bias”. Criminal Justice 22.3 (2007): 60-61.
Kneedler, Edwin S., and Letter N. Douglas. In the Supreme Court of the United States. 2010. Web.
Martin, Shawn. Mayfield v. United States (2009). Web.
Paez, Richard A., and Rawlinson, Johnnie. United States Court of Appeals for the Ninth Circuit. 2009. Web.
US Department of Justice. A Review of the FBI’s Handling of the Brandon Mayfield Case. 2006. Web.