Chris Davey

Legal Problems of Human Rights

The Undeserving: Value Ranking in a Time of Terror and Security
Former Vice-President Dick Cheney, advocate of the so-called “War on Terror” made
the following statement regarding would-be terrorists found within the borders of the US
government, ‘These people are criminals illegally entering into the United States, killing our
citizens. They do not deserve the same guarantees and safeguards that would be used for an
American citizen going through the normal judicial process.’1 Cheney’s remarks embody the
idea of ranking the value of individuals as lower than that of security. In the War on Terror
suspects have been labelled as undeserving of the ‘normal judicial process’ and human rights.
Many terror suspects have found themselves locked away without formal charges, their rights
subordinated to this idea of American security. In the context of terrorism and security this
paper will address this change in value ranking and subsequent consequences for the rights of
the undeserving. This topic will be approached by successively analyzing the developments
in US value ranking before and after 9/11, the continuance of post-9/11 value ranking, and its
place in the ongoing War on Terror.
Analysing value ranking in the context of security throws important light onto how
life is valued and ranked in the political arena. The intrinsic value of human life is
fundamental to liberal democracies. This basic foundation is enshrined in the Universal
Declaration of Human Rights. Articles one and three state that human beings are ‘born free
and equal in dignity and rights’, therefore having an intrinsic claim on ‘life, liberty, and
security of person.’2 Ranking the value of a person’s life, or claim to liberty and security
over another’s, questions this very basis of intrinsic value. When terror suspects are
arbitrarily deemed undeserving of rights they are drained of intrinsic value. Such value
ranking reframes individuals’ dignity and rights as means to others’ security.3 The greatest
problem with giving such prominence to security is that it tramples the right to life, thereby
undermining liberal principles, which has led to the violation of the prohibition of torture.
The context of security also draws a clearer picture of more consistent principles and
ideology that act as a basis for value ranking, whereas the day-to-day value ranking of
individual actors is somewhat more arbitrary and not as adherent to a specific value system,
but a patchwork of everyday choices and activities. Broadly speaking, the value ranking of
security actors has a greater impact on criminal suspects and human rights generally. The

1
Dick Cheney, quoted in Randall P. Peerenboom, ‘Human Rights and Rule of Law: What’s the
Relationship?’ Georgetown Journal of International Law 36, (2005): 136.
2
‘United Nations Universal Declaration of Human Rights,’ United Nations Documents,
http://www.un.org/en/documents/udhr/ [accessed 3 April 2010].
3
Amanda R. Beattie, ‘Security and Insecurity: Intrinsically Valuing Life & the Threat of Terrorism,’
presented at the International Studies Association, 17 March 2004, 3.
 Chris Davey
Legal Problems of Human Rights
security concerns emerging from the wake of the 2001 terror attacks on the US demonstrate
this type of value ranking.
Value in a Time of Terror
Falling towers in New York and a smouldering Pentagon spurred seizures of emotion
and scrambles for policy and retribution on the part of many American people and
politicians. Within a month of the attacks the Bush administration started fulfilling the
heavily worded warnings of Vice-President Cheney. The administration authorized the use
of military courts as a method of trying the burgeoning ranks of suspected terrorists. These
special courts were closed to the US domestic judicial system and those to stand trial, if they
did, were restricted from access to evidence and charges on grounds of national security.4
The securing of these prisoners became centred in Guantanamo Bay where initial reporting
showed that within a year of 9/11 nearly six hundred foreign nationals from forty-three
countries were being detained without charges.5
Crafting the War on Terror with the framework of extra-judicial processes and
military courts, trampled almost instantly the international norms of rights to equality before
the law, recognition of personhood before the law and the right to a fair trial. Increasing
numbers of suspects picked-up during military campaigns in Afghanistan and Iraq, not to
mention the undisclosed extraordinary renditions, only serve to multiply these problems.6
The declared intention of President Bush that enemy combatants were to be held until
succession of fighting further closed the prison door on hundreds of suspects. 7 The inflation
of security concerns in the US came at the cost of the value previously placed in equal rights
before the law. These measures place the security of American subjects above those of other
nationalities including even American citizens suspected of terrorist activity.
Following this trend, the Patriot Act authorized extra-warrant police activities against
American citizens. This legislation sought to increase surveillance powers, enabling the
government to investigate and act without the constraint of reasonable suspicion to prevent
terrorism and capture more so-called combatants.8 Questioning the balancing of liberty and
security, Jeremy Waldron describes these legal measures as resulting only in ‘symbolic

4
Laura Dickinson, ‘Legal Processes to Fight Terrorism: Detentions, Military Commissions,
International tribunals, and The Rule of Law,’ The Southern California Law review 75 (2002): 1410.
5
Katharine Seelye, ‘Guantanomo Nay Faces Sentence of Life as Permanent U.S. Prison,’ NY Times, 12
Sept. 2002.
6
See Articles 6, 7 and 8 of the Universal Declaration of Human Rights (UNDHR). These declared
rights serve as a starting point for international norms regarding the basic duties that establish obligations of
due-process.
7
The Economist, ‘The Freedom Paradox,’ Special Report: September 11th 2001, Civil Liberties, 9 Feb.
2006.
8
‘The Freedom Paradox.’
 Chris Davey
Legal Problems of Human Rights
gains’.9 Pitting liberty against security in a balancing act of security epitomizes the problem
of value ranking. The inherent value and liberty of individuals is taken out of the foundation
of liberal democracy and put into the bricks and mortar of society. Citizens accommodated
the trade-off of certain liberties for the administration’s claims of security. By doing so
Americans were not conscious of the warning that, ‘we should be careful about giving up our
commitment to the civil liberties of a minority, so that we can enjoy our liberties in greater
security.’10 Such laws continued to add to the metamorphosis of value ranking that the
growing Bush Doctrine of security offered. Thus the dichotomy of seeking this kind of
security and “fighting for liberty” arises. By accepting these ‘symbolic gains’, potentially the
people themselves become the means to safety and security not the ends that they should be,
thereby lowering the value that US officials placed in their own people in general, let alone
that of foreign nationals suspected of terrorism.11 This problem becomes further complicated
with incidences of domestic terrorism such as the recent foiled attack in New York’s Times
Square.12
Historic examples of US wartime security value ranking demonstrate a pattern of
denigrating the value placed in the lives of human beings, even her own citizens. As a
foreshadowing of post-9/11 politics, following the attack on Pearl Harbour, many Japanese
immigrants and Japanese Americans were detained and held upon suspicion of being threats
to national security.13 The War Relocation Authority also interned many Americans of
German and Italian descent for the same reason.14 The military campaign in the Pacific
theatre of World War Two was also fraught with US servicemen, encouraged by popular
sentiment and propaganda, who considered the lives of their enemy to be of significantly
lower value. The valuing was characterized by the military posters that encouraged the
sentiment that the only good “Jap” was a dead one. 15 In Vietnam the infamous My Lai
massacre, perpetrated under orders to ‘search and destroy’ those in the village demonstrates

9
Jeremy Waldron, ‘Security and Liberty: The Image of Balance,’ The Journal of Political Philosophy
11, no. 2 (2003): 209.
10
Waldron, 210.
11
Ibid...
12
BBC, ‘Times Square bomb suspect in court on terrorism counts,’ BBC 18 May 2010,
http://news.bbc.co.uk/2/hi/americas/8690981.stm [accessed 25 May 2010].
13
Todd T. Kunioka and Karen M. McCurdy, ‘Relocation and Internment: Civil Rights Lessons from
World War II,’ Political Science and Politics 39, no. 3 (2006): 503.
14
Kunioka and McCurdy, 506.
15
Office for Emergency Management, ‘Stay on the job until every murdering Jap is wiped out! 1941-
1945’ National Archives, http://arcweb.archives.gov/arc/action/ShowFullRecordLinked/ [accessed 25 April
2010]. This particular item calls for servicemen to respond blood for blood in retaliation for the infamous
Bataan Death March of 1942.
 Chris Davey
Legal Problems of Human Rights
the ferocity with which enemy combatants and their suspected supporters were treated.16
These events were all imbued with racism and a willingness to subordinate the rights of US
citizens and foreign nationals for apparent gains in security. Prior to 9/11 this trend had not
become a matter of policy but more a result of culture and tradition. Developments in the US
as part of the War on Terror entrenched this historical trend into law legalising patterns of
preventative action based upon suspicion and low value ranking.
Similarly, the Abu Ghraib incident brought to light by the media haunts the noble
cause of security and freedom. This event coalesces with the more recent approach to
security and crime management known as ‘risk control’. Rising to prominence in the 1970s,
this practise of law enforcement aims to reduce risk by targeting suspected groups and their
behaviour with preventative measures.17 However, this risk-centred approach has dire
consequences for those within suspect groups. The racism that has been prevalent
throughout the history of the US further adds to the endangering of minorities, such as
Muslims, who are increasingly viewed with suspicion as the target group from which
terrorists derive. Performed with impunity, the actions at Abu Ghraib targeted those
imprisoned on suspicion of terrorism. The actions of a few servicemen displayed in graphic
terms the consequences of combining lower-value ranking of suspected terrorists, risk control
management, and the prejudice that has often been present in US war efforts.18
Abu Ghraib brings this analysis to the practise and policy that has most undermined
individual value and liberal democracy: torture. Those considered the most undeserving of
terror suspects have been caught in the net of politicized and legal wording that has created
new norms of torture in US policy. It is this aspect of the war that holds the most challenging
problem of value ranking. Two key legal documents known as the Haynes and Bybee
memorandums for use by the US Justice Department supported crossing the traditional
boundaries and violation of the absolute right that prohibits torture.19 These official
guidelines served to place even lower value on terror suspects. Not only were legal rights
being bypassed through detainment but these endorsements of torture, or “intensive
interrogation techniques”, trampled on the personhood and the dignity of the individual that
the prohibition of torture seeks to protect.20
16
‘The My Lia Massacre,’ The American Experience, PBS,
http://www.pbs.org/wgbh/amex/vietnam/trenches/my_lai.html [accessed 17 April 2010].
17
Anastassia Tsoukala, ‘Security, Risk and Human Rights: A Vanishing Relationship?’ CEPS Special
Report, Sept 2008.
18
Amnesty International USA, ‘Human dignity denied: Torture and Accountability in the “War on
Terror”,’ 27 October 2004, http://www.amnestyusa.org/document.php?
lang=e&id=9DEF4263FC2E35CA80256FE7004FE4C0 [accessed 17 April 2010].
19
Barbara Hudson, ‘Justice in a Time of Terror,’ British Journal of Criminology 49, (2009): 707.
20
Hudson, 707.
 Chris Davey
Legal Problems of Human Rights
Barbara Hudson discusses the justification for such techniques and how the logic of
torture falls short of reality. Many supporters of the War on Terror claim the “ticking time
bomb” scenario demonstrates that in order to save the lives of many the lives or dignity of
few, or even one, must be abused in order to uncover “the bomb” before greater harm occurs.
Hudson describes the main problem with this scenario is that it ‘cheats’ by making
assumptions that are taken for fact: the actual existence of the bomb, and that the captive
knows and is willing to disclose where the bomb is under a certain amount of pressure.
Additionally, there is the question of how many suspects one will torture to find the illusive
bomb,

If there is a group of captives and one or some of them might know something,
should they all be tortured, even with the risk that only one or only a few of them
might know and so some are being tortured who have no knowledge? How many
lives must potentially be saved to justify the torture of one captive?21

This is precisely the point when considering the problems of value ranking imposed upon
suspects by this level of security reasoning: how many rights must be trampled before
suspicion is answered or safety is assumed secure? Torturing for information regarding
terror attacks or intelligence produces more harm by way of direct abuse upon suspects, than
upon the possible indirect security and safety. Low value ranking of the lives and dignity of
suspects is morally costly and produces little in the way of concrete outcome.
Post Bush Politics: Outcomes and Risks of Value Ranking
This section will briefly address a broad the problems that the above developments of value
ranking in the War on Terror pose for the principles of liberal democracy, current
developments under the Obama administration, and the ripples that the War on Terror has
created for the future of security and warfare beyond the US.
Michael Ignatieff readily summarizes the challenge faced by liberal democracies
because of post-9/11 developments in security value ranking, ‘When (torture is) committed
by a state, (it) expresses the state’s ultimate view that human beings are expendable. This
view is antithetical to the spirit of any constitutional society whose raison d’etre is the
control of violence and coercion in the name of human dignity and freedom.’22 Degrading
the value of those deemed undeserving not only hampers the purpose for liberal democracies
in fighting terrorism, but ultimately serves to undermine liberal legitimacy. Hudson adds
that,

21
Ibid., 709.
22
Michael Ignatieff, The Lesser Evil: Political Ethics in an Age of Terror (Edinburgh: Edinburgh
University Press, 2004), 143.
 Chris Davey
Legal Problems of Human Rights

Liberal democratic values cannot be discarded when convenient for the state to
preserve its liberal democratic nature. If they mean anything and are taken seriously,
rights and freedoms need to be defended when they are endangered by terror, and by
states’ self-defensive reactions to terror. States need to defend liberal values against
the temptations of nihilism.23

The changes in policy and strategy by the Bush administration have proved to be results of a
consequentialist approach. Individual lives, being expendable, are assigned value according
to their ability to bring security not for their inherent dignity and rights. 24 Security and
safety have been accorded a higher ranking than the individual freedom and liberty that the
War on Terror has sought to protect.
President Obama’s security policies have ebbed and flowed regarding this matter.
Despite the hope raised by the promises of closing the Guantanamo Bay prison, the
continuance of the War on Terror in Afghanistan and restrictions of legal rights to terror
suspects show little renewal of respect for the rights of the undeserving. Obama’s first
Executive Order called for the closure of Guantanomo as soon as was ‘practicable’.25 The
order cites the need for investigation into pending cases, possible transference of detainees,
and includes a recognition of habeas corpus for all interned in the camp.26 However, more
than a year after this announcement the camp still functions in its original capacity holding
196 inmates imprisoned awaiting further trial or release.27 Casting a looming shadow over
the plans for closing Guantanamo is the expanding Bagram detention centre in Afghanistan.
This location holds more than a thousand suspects, who it is reported, have been subjected to
the continuance of the Bush policies of torture and denial of legal rights.28 The continued
devaluing of the rights and dignity of terror suspects under the Obama administration only
serves to further replace human rights norms with post-9/11 security value ranking.
In the battlefield of Afghanistan the value of human life is pushed increasingly into
the footnotes of the War on Terror. Two issues are important here in considering the pursuit
of the War in Afghanistan: the drone missile attacks and long term military operations in

23
Hudson, 712.
24
Beattie, 3.
25
Barack Obama, ‘Closure of Guantanamo Detention Facilities,’ The White House, 22 Jan. 2009,
http://www.whitehouse.gov/the_press_office/closureofguantanamodetentionfacilities/ [accessed 15 April 2010].
26
Obama, ‘Closure of Guantanamo.’
27
BBC News, ‘Q&A: Closing Guantanamo,’ BBC, 23 Jan 2010,
http://news.bbc.co.uk/2/hi/americas/7844176.stm [accessed 15 April 2010]. It should also be noted that since
suspects were initially held in Guantanamo only three out of the 775 inmates have been convicted by military
tribunal.
28
Stephen Foley, ‘Obama denies terror suspects right to trial,’ The Independent, 22 Feb 2009,
http://www.independent.co.uk/news/world/politics/obama-denies-terror-suspects-right-to-trial-1628958.html
[accessed 17 April 2010].
 Chris Davey
Legal Problems of Human Rights
combating terrorism. During the summer of 2009 six drone operations led to the deaths of
over 175 Afghans.29 While these attacks were aimed at high-ranking Taliban and militant
suspects, collateral damage was unavoidable. However, UN Special Rapporteur on
Extrajudicial Executions, Philip Alston, has claimed that such attacks represent a danger to
US compliance with international humanitarian law.30 These summary executions of Taliban
suspects are carried out with the accepted deaths of bystanders. Bystanders are therefore
assumed complicit in terrorist activity; extending the value ranking of generally confirmed
Taliban actors to these individuals in a manner akin to the application of risk control.
Targets are eliminated along with non-combatant members of the target group; making
collateral deaths a direct result of the value assigned to combatants in the War on Terror.
The use of missile drones is ongoing within the War on Terror, a war that is swiftly
becoming a long term military conflict. The Department of Defence’s 2006 Quadrennial
Review cites Mr. Bush as stating that Afghanistan will amount to ‘a lengthy campaign,
unlike any other we have ever seen.’31 The Review extrapolates on this general comment
claiming that the US has now proven itself capable of inland and global operations necessary
for continued war against terrorism.32 Ambassador to Afghanistan Richard Holbrooke has
confirmed this long war approach as part of the continuing War on Terror and US military
presence.33 Tragically, with the increased use of drone technology taking broad swipes at
Taliban operatives and bystanders, a long term war in Afghanistan appears to be geared up to
only expand the Bagram prison, increase collateral killings, and enhance the post-9/11 value
ranking as part of a de-facto war strategy.
Ripples throughout the globe have been felt as a consequence of US unilateralism and
security value ranking. Countries like Russia and others in central Asia, with Islamic
populations, have used the precedent of post-9/11 value ranking to more aggressively pursue
their own terror suspects.34 This trend is particularly acute in Pakistan where the military has
taken upon itself to subverting human rights and the authority of the civilian government of

29
D Suba Chandran and Kate Swanson, ‘Drone of War: American Strategies across the Durand Line,’
Institute of Peace and Conflict Studies 111, July, (2009), 1.
30
UN News Centre, ‘UN rights expert voices concern over use of unmanned drone by United States,’
UN News Service, 28 Oct 2009, http://www.un.org/apps/news/story.asp?NewsID=32764&Cr=alston&Cr1
[accessed 20 April 2010].
31
Donald Rumsfeld, Quadrennial Defence Review Report, 6 Feb 2006, Pentagon, Washington D.C., 9.
32
Rumsfeld, 10-11.
33
Tom Hayden, ‘Holbrooke Projects Long Occupation of Afghanistan, Pakistan,’ Tom Hayden, 20
Aug 2009, http://tomhayden.com/articles/2009/8/20/holbrooke-projects-long-occupation-of-afghanistan-
pakistan.html [accessed 20 April 2010].
34
Tanya Lokshina, ‘Human Rights in Russia Hearing May 6, 2010,’ North Caucasus Panel Testimony,
Human Rights Watch Russia Office, http://www.hrw.org/en/news/2010/05/06/human-rights-russia-hearing-
may-6-2010 [accessed 22 April 2010].
 Chris Davey
Legal Problems of Human Rights
President Zardari. Human Rights Watch has reported that although the government
acknowledged the disappearances of hundreds of suspects during the prior military rule, the
armed forces continue to prevent investigation and searches for these disappeared
individuals.35 The relatively new government has also begun to follow suit with the military
in the face of continuing militant attacks. In October 2009, legislation authorized by
President Zardari allows the ‘preventative detention’ of terror suspects; intelligence and
military authorities then have a 90-day window within which to extract information that
justifies their arrest. This extraction often results in torture.36 These actions along with
continued drone bombing affecting hundreds of civilians in North-west Pakistan act in
concert to conjure up a false sense of security by consistently lowering the value placed upon
suspected terrorists and their neighbours.37
Conclusion
US anti-terror and security policies have turned the War on Terror’s quest for upholding
democracy against itself. Winston Churchill said the following regarding the intertwinement
of society, prisons, and the so-called undeserving, ‘The mood and temper of the public in
regard to the treatment of crime and criminals is one of the most unfailing tests of the
civilisation of any country. A calm, dispassionate recognition of the rights of the accused,
and even of the convicted criminal, a constant heart-searching by all charged with the duty of
punishment.’38 Churchill here summarizes the customary and legal norms that have been
trampled by post-9/11 value ranking. Through the devaluing of those Cheney labelled as
undeserving the US government has led the public against those suspected of terrorist acts.
The rights of those suspected are over-shadowed by the legislation and memorandums that
have built-up the current practises of detainment and torture. The victims of post-9/11 value
ranking are the US citizens and foreign nationals, guilty or not, suspected of criminal acts
and the citizenry who are attracted by such theatrical gains in what Waldron referred to as
‘symbolic’ security. Most damaging, however, is the deconstruction of fundamental liberal
democratic principles and human rights norms. If how we treat the criminals of society is a
test of civilization, then the US government and security authorities are setting a failing
standard.

35
Human Rights Watch, ‘Pakistan: Military Undermines Government on Human Rights,’ 20 Jan. 2010,
http://www.hrw.org/en/news/2010/01/20/pakistan-military-undermines-government-human-rights [accessed 25
April 2010].
36
HRW, ‘Pakistan: Military Undermines Government.’
37
BBC News, ‘US drone attack in Pakistan kills 15,’ 17 Jan 2010,
http://news.bbc.co.uk/2/hi/8464009.stm [accessed 25 April 2010].
38
Winston Churchill, speech in House of Commons 20 July 1910, cited in Shami Chakrabarti,
‘Reflections on Zahid Mubarek Case,’ Community Care, July 2006.
 Chris Davey
Legal Problems of Human Rights

Works Cited
Amnesty International USA. ‘Human dignity denied: Torture and Accountability in the “War
on Terror”.’ 27 October 2004. http://www.amnestyusa.org/document.php?
lang=e&id=9DEF4263FC2E35CA80256FE7004FE4C0 [accessed 17 April 2010].
 Chris Davey
Legal Problems of Human Rights
Beattie, Amanda R. ‘Security and Insecurity: Intrinsically Valuing Life & the Threat of
Terrorism.’ Presented at the International Studies Association. 17 March 2004.

Chandran, D Suba and Kate Swanson. ‘Drone of War: American Strategies across the
Durand Line.’ Institute of Peace and Conflict Studies 111, July, (2009): 1-4.

Churchill, Winston. Speech in House of Commons 20 July 1910. Cited in Shami

Chakrabarti. ‘Reflections on Zahid Mubarek Case.’ Community Care. July 2006.

Dickinson, Laura. ‘Legal Processes to Fight Terrorism: Detentions, Military Commissions,

International tribunals, and The Rule of Law.’ The Southern California Law review
75 (2002): 1407-1489.

Hayden, Tom. ‘Holbrooke Projects Long Occupation of Afghanistan, Pakistan.’ Tom

Hayden. 20 Aug 2009. http://tomhayden.com/articles/2009/8/20/holbrooke-projects-
long-occupation-of-afghanistan-pakistan.html [accessed 20 April 2010].

Hudson, Barbara. ‘Justice in a Time of Terror.’ British Journal of Criminology 49, (2009):
702-717.

Human Rights Watch. ‘Pakistan: Military Undermines Government on Human Rights.’ 20

Jan. 2010. http://www.hrw.org/en/news/2010/01/20/pakistan-military-undermines-
government-human-rights [accessed 25 April 2010].

Ignatieff, Michael. The Lesser Evil: Political Ethics in an Age of Terror. Edinburgh:
Edinburgh University Press, 2004.

Kunioka, Todd T. and Karen M. McCurdy. ‘Relocation and Internment: Civil Rights
Lessons from World War II.’ Political Science and Politics 39, no. 3 (2006): 503-
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Lokshina, Tanya. ‘Human Rights in Russia Hearing May 6, 2010.’ North Caucasus Panel
Testimony. Human Rights Watch Russia Office.
http://www.hrw.org/en/news/2010/05/06/human-rights-russia-hearing-may-6-2010
[accessed 22 April 2010].

Obama, Barack. ‘Closure of Guantanamo Detention Facilities.’ The White House. 22 Jan.
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http://www.whitehouse.gov/the_press_office/closureofguantanamodetentionfacilities/
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Office for Emergency Management. ‘Stay on the job until every murdering Jap is wiped out!
1941-1945.’ National Archives.
http://arcweb.archives.gov/arc/action/ShowFullRecordLinked/ [accessed 25 April
2010].
 Chris Davey
Legal Problems of Human Rights

Peerenboom, Randall P. ‘Human Rights and Rule of Law: What’s the Relationship?’
Georgetown Journal of International Law 36, (2005): 1-152.

Rumsfeld, Donald. Quadrennial Defence Review Report. 6 Feb 2006. Pentagon,

Washington D.C.

The Economist. ‘The Freedom Paradox.’ Special Report: September 11th 2001, Civil
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http://www.pbs.org/wgbh/amex/vietnam/trenches/my_lai.html [accessed 17 April
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Tsoukala, Anastassia. ‘Security, Risk and Human Rights: A Vanishing Relationship?’ CEPS
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http://www.un.org/en/documents/udhr/ [accessed 3 April 2010].

UN News Centre. ‘UN rights expert voices concern over use of unmanned drone by United
States.’ UN News Service. 28 Oct 2009. http://www.un.org/apps/news/story.asp?
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Waldron, Jeremy. ‘Security and Liberty: The Image of Balance.’ The Journal of Political
Philosophy 11, no. 2 (2003): 191-210.