Roger C. S. Lin et. al. v. United States of America [Part 2]

  1. We are well aware of the US constitutional arguments. Dr. Lin’s legal team has done extensive research on which constitutional provisions do actually apply in a US overseas territory such as Taiwan.

In our court documents, this has been stated as follows:

[color=#4000BF]RELIEF REQUESTED: Considering that the judicial branch has the authority and obligation to preserve the Constitutional rights of persons subject to the jurisdiction of the United States, whether or not such persons are United States citizens, non-citizen nationals, or aliens, Plaintiffs/Appellants respectfully pray that the Court enter an Order declaring that:

Plaintiffs/Appellants, by virtue of living in a territory subject to the jurisdiction of the United States,

  • have fundamental rights under United States laws, including the United States Constitution.

  • have the Fifth Amendment right and Fourteenth Amendment right against deprivation of life, liberty, or property, without due process of law.

  • have the Eighth Amendment right against cruel and unusual punishment, including deprivation of a recognized nationality and being “stateless.”

  • have the First Amendment right to petition the government for a redress of grievances.

  • have the Fourteenth Amendment right of equal protection of the laws, etc.

  • may not be deprived of the Fifth Amendment right to travel (including the right to apply for a passport) without due process of law, which requires a notice and a hearing. [/color]

  1. We are well aware that just because Taiwan is subject to the jurisdiction of the United States, it is not “part of” the United States. However, the recent Guantanamo cases in the US Supreme Court have confirmed that some constitutional rights apply even in such circumstances.

  2. In IceEagle’s analysis, there are often references to the “Republic of China,” but please be aware that this terminology is not recognized under the Taiwan Relations Act or under current US State Dept. guidelines for dealing with Taiwan. In other words, in the eyes of the US Executive Branch, there is no country called “Republic of China.” HENCE, when IceEagle affirms that ROC institutions are legitimate in the eyes of the US … I would say that it is exactly this viewpoint which can be seriously challenged.

That the US Congress has the right to recognize the ROC’s current administration over Taiwan as lawful is incorrect however, because foreign relations are decided upon by the US President.

In Dr. Lin’s analysis, it is exactly this “presumption of ROC legitimacy” which must be challenged in the US court system, in order to fully protect the civil rights of native Taiwanese people. Dr. Lin’s case is a very serious legal challenge to the current “ambiguous situation.”

  1. The District Court already ruled on March 18, 2008, that native Taiwanese people have been essentially stateless for nearly 60 years. (It is recognized that Japan had sovereignty over Taiwan until April 28, 1952, and native Taiwanese people were of the Japanese nationality up until the Spring of 1952.)

As long as it can be proved that the US is the principal occupying power of Taiwan (clearly stated in SFPT Article 23(a) and confirmed by Article 4(b)), then the “US national” determination is automatic under the US immigration statutes. If you want more details, you should read the Nov. 3 and Dec. 17, 2008, court briefs by the Plaintiffs/Appellants.

  1. IceEagle stated that "The Republic of China, as one of the Allied Powers, worked with the US to take Taiwan away from Japan and restore it to the sovereignty of the ROC . . . . " but Dr. Lin does not agree to this. All military attacks against Taiwan in the WWII period were conducted by US military forces. The ROC didn’t participate, nor was Taiwan in the “China Theater.”

The USA was the conqueror of Taiwan, hence it would be wholly expected that the United States would be the principal occupying Power over Taiwan. The notion that there was a transfer of Taiwan’s sovereignty to China on the Oct. 25, 1945 date of the surrender ceremonies is merely Chinese propaganda. None of the Allies had any such recognition.

  1. IceEagle stated that “Although the intent was for the US and Japan to sign a treaty to formally restore sovereignty of Taiwan to the ROC, this failed to come to pass because of the rise of the PRC on the mainland.” We believe that it is more complicated than this. Most importantly, by moving its central government to occupied Taiwan in December 1949, the ROC has become a government in exile. The Allies were obviously not going to award a “territorial cession” to a government in exile.

  2. IceEagle stated “. . . the US has lawfully allowed the ROC to administer Taiwan.” Dr. Lin’s court case is serving to challenge this assumption. Dr. Lin feels that the ROC’s continuing administration of Taiwan after April 28, 1952 is a gross miscarriage of justice. Taiwan was not awarded to the ROC in the SFPT. (The Treaty of Taipei is merely a subsidiary treaty under the SFPT, and did not award Taiwan to the ROC either.)

  3. Dr. Lin is arguing that the native Taiwanese people are eligible for certain fundamental rights under the US Constitution, and the recent Guantanamo rulings also support such an interpretation. In terms of “US jurisdiction,” Taiwan’s status is on a higher level than Guantanamo. Under the SFPT, it can be successfully argued that Taiwan has no government, because the ROC is not recognized as the legal government of Taiwan. The US Executive Branch does not recognize the ROC as a “state” in the international community.

Looking at Boumediene v. Bush, the key issue in applying this to Taiwan is whether or not it has a unique set of laws as compared to the US. The analogy with Scotland and England is drawn here - even though Scotland was part of England, habeas corpus did not apply to Scotland because Scotland had its own set of laws.

The case of Reid v Covert, while not an Insular case, made reference to them. Congress has the power to make up rules and regulations for territories with different traditions. This doesn’t apply to Guantanmo (which is a US Naval Base) but it could apply to Taiwan.

But what seems to be of uttermost importance here, is that the ROC having lawful authority by the US to administer Taiwan. If the ROC was granted the authority, then the US constitution doesn’t apply since the ROC is granted the ability to apply its own laws and its own traditions, rather than being required to follow the US ones. If the ROC did not have lawful authority, then the Court would likely prefer to have the US constitution apply to Taiwan rather than leaving a US territory in legal limbo with no laws.

The Republic of China is refered to as such by name in the Sino-American Mutual Defense Treaty. At this time the US still maintained diplomatic relations with the ROC.

Although the US does not currently refer to the Republic of China by that name (as required by the PRC), Section 2a of the Taiwan Relations Act makes reference to the ROC by name as the “governing authorities on Taiwan”.

ait.org.tw/en/about_ait/tra/

That the US no longer refers to the ROC by name (for political reasons), makes no difference, as the law is clear on exactly who is currently administering Taiwan.

As the Sino-American Mutual Defense Treaty is no longer in effect, its status as lawful is no longer relevant.

The TRA makes it clear that there are no foreign relations between the ROC/Taiwan and the US, so there is no infringement by Congress over the powers of the US President. So, I conclude that the TRA is lawful.

In any case, if Taiwan is a US territory with US sovereignty, it is not clear why the exclusive right of the US president to handle foreign relations would come into play here.

Since Taiwan was given to the US by the SFPT, and the US allowed the ROC to lawfuly administer Taiwan, this argubly makes the ROC the legitimate government of Taiwan, at least currently. Such right is revokable by the US at the disgression of the US perhaps, but there is no obligation for the US to do so at the current time.

Unless the administration of Taiwan by the ROC is unlawful, and that the US is not legally empowered to allow the ROC to function over Taiwan as it currently does. But this isn’t the case.

I’m not sure if that ruling was entirely correct, since from 1952 to 1979, the US should have recognized the possession of ROC nationality as legally accorded to them by the Treaty of Taipei as a subsidary Treaty under the SFPT.

After 1979, the possession of ROC nationality is no longer recognized.

I’ll make a second post in reply to this.

The Potsdam and Cairo Declarations make it clear this was the original intent. That the US did all the work has no effect on this.

We are both agreed that the sovereignty was never transfered to the ROC as was originally intended, but it is clear that this was the original intent.

Why is this obvious?

By granting the ROC the lawful authority to administer Taiwan, the US did so in all but name.

That the US has lawfully allowed the ROC to administer Taiwan, is different from stating that Taiwan was awarded to the ROC. The latter implies a transfer of legal title.

[quote=“Hartzell”]
8. Dr. Lin is arguing that the native Taiwanese people are eligible for certain fundamental rights under the US Constitution, and the recent Guantanamo rulings also support such an interpretation. In terms of “US jurisdiction,” Taiwan’s status is on a higher level than Guantanamo. Under the SFPT, it can be successfully argued that Taiwan has no government, because the ROC is not recognized as the legal government of Taiwan. The US Executive Branch does not recognize the ROC as a “state” in the international community.[/quote]

Taiwan has “wholly different dissimilar traditions and institutions” while Guantanamo is founded on an American institution.

The status of the ROC having recognition as a sovereign state is irrelevant to the status of the ROC having lawful authority to administer the affairs of Taiwan on behalf of the US.

If the US has soverignty over Taiwan (as accorded by the SFPT), and the ROC has lawful authority to administer the affairs of Taiwan on behalf of the US, then it follows that Taiwan has a legal government.

[quote=“IceEagle”][quote=“Hartzell”]As long as it can be proved that the US is the principal occupying power of Taiwan (clearly stated in SFPT Article 23(a) and confirmed by Article 4(b)), then the “US national” determination is automatic under the US immigration statutes. If you want more details, you should read the Nov. 3 and Dec. 17, 2008, court briefs by the Plaintiffs/Appellants.
[/quote]

I’ll make a second post in reply to this.[/quote]

You have a very strong argument. What counts here is a) that the native Taiwanese are entitled to protection by the US and b) that they have permanent allegiance to the US.

Furthermore, it seems that being entitled to protection by the ROC and holding permanent allegiance to the ROC has no bearing on either a) or b).

It would seem that a) fails to apply to Taiwan, since the protection by the US is conditional. President Bush has stated that should Taiwan declare independence unilaterally, the US will not protect Taiwan from an attack from the PRC. However, since this is President Bush, that should be taken with a grain of salt. The wording of the Taiwan Relations Act suggests it is neutral on this issue - the US will help Taiwan keep itself ready for self defense and keep its own forces ready as well, but there isn’t an obligation on the US to act on behalf of Taiwan in the event of an invasion.

As for b), Sections 4(b)(1) states that all laws of the US relating to foreign countries will apply in the same capacity to Taiwan, which is inconsistent with the idea that Taiwan holds permanent alliegiance to the US. 4(b)(2) applies the same stipulations to the executive branch of the US.

I want to make note here that it is of the uttermost importance to this case that not only are native Taiwanese permanent residents under the sovereignty of Taiwan, and that they are US nationals, but also that they are granted special rights that are not currently covered by what the ROC currently gives them.

Without that grant, the status of US nationals and the status of the sovereignty of Taiwan is moot for this case since it makes no difference. If a court can somehow conclude that no such grant would exist even if the above were true, then the court can avoid coming to a decision on them.

[quote=“IceEagle”] . . . As for b), Sections 4(b)(1) states that all laws of the US relating to foreign countries will apply in the same capacity to Taiwan, which is inconsistent with the idea that Taiwan holds permanent alliegiance to the US. [/quote] This goes back to the laws of war. As “US occupied territory,” Taiwan is foreign to the USA.

Hence, there is no contradiction.

[quote=“IceEagle”]The status of the ROC having recognition as a sovereign state is irrelevant to the status of the ROC having lawful authority to administer the affairs of Taiwan on behalf of the US.

If the US has soverignty over Taiwan (as accorded by the SFPT), and the ROC has lawful authority to administer the affairs of Taiwan on behalf of the US, then it follows that Taiwan has a legal government.[/quote]
The ROC on Taiwan is conducting numerous governmental affairs in a way which is inconsistent with its non-sovereign status. It is, therefore, in Dr. Lin’s view, acting illegally.

Heh, ok, looks like we’re going to have to wait at least another year to hear anything new on this:

examiner.com/x-1969-Boston-P … and-rocket

On a side note:

caselaw.lp.findlaw.com/scripts/g … &invol=356

[quote]
The status of the Republic of China in our courts is a matter for determination by the Executive and is outside the competence of this Court. Accordingly, we start with the fact that the Republic and its governmental agencies enjoy a foreign sovereign’s immunities to the same extent as any other country duly recognized by the United States. See Guaranty Trust Co. v. United States, 304 U.S. 126, 137 -138.[/quote]
So I take this to mean that the DOJ can simply get an official statement from the Department of State stating something like: “We recognize the Shanghai Communique and the Joint Communique as having legal standing and thus formally recognize Chinese sovereignty over Taiwan.” and then the court would be enjoined from ruling otherwise - i.e. unable to rule that Taiwan is under US sovereignty, since the Department of State has ultimate authority over that.

(Or they might say something like “We recognize the claims of sovereignty of both the People’s Republic of China and the Republic of China but because we have not determined which claim is yet superior, accord the status of sovereignty to be currently undecided. We recognize only Chinese sovereignty over Taiwan and state that the US currently does not hold any claim or title of sovereignty over Taiwan.” but whatever they say, it’ll effectively end with this case being dismissed.)

So it seems that it is the US Department of State, not the US court system, that has final say over whose sovereignty is recognized, and this could easily apply to claims of sovereignty over contested areas as well.

Your analysis is very much out of date. A 1960 court case confirmed that the US has never recognized ROC sovereignty over Taiwan.

Office/Agency: D.C. Circuit Court
title: Rogers v. Sheng, (D.C. Circuit, 1960):
date: 1960
subject: Status of Formosa
item: The court described the status of Formosa as follows: "Following World War II, Japan surrendered all claims of sovereignty over Formosa. But in the view of our State Department, no agreement has ‘purported to transfer the sovereignty of Formosa to (the Republic of) China’… "
(source: D.C. Circuit Court records)

A CRS Report from 2007 confirmed that the US has never recognized PRC sovereignty over Taiwan.

Office/Agency: Congressional Research Service
title: China/Taiwan: Evolution of the “One China” Policy
date: July 9, 2007
[ In the Summary at the beginning of that report the following points were made – ]
quote:
(1) The United States did not explicitly state the sovereign status of Taiwan in the three US-PRC Joint Communiques of 1972, 1979, and 1982.
(2) The United States “acknowledged” the “One China” position of both sides of the Taiwan Strait.
(3) US policy has not recognized the PRC’s sovereignty over Taiwan;
(4) US policy has not recognized Taiwan as a sovereign country; and
(5) US policy has considered Taiwan’s status as undetermined.
(source: CRS Report for Congress, July 9, 2007 – China/Taiwan: Evolution of the “One China” Policy)

Numerous other US State Dept. documents have also confirmed these “findings.”

Determining Taiwan’s status

by Roger C. S Lin
taipeitimes.com/News/editori … 2003435824

I was just stating a hypothetical possibility. Until and unless the Department of State does issue said statement or similar to the DOJ for the court case, it’s purely hypothetical.

That said, in this scenario, I don’t see how one could continue to make the claim of US sovereignty over Taiwan if the Department of State does issue said statement. The fact that they’ve never said it before wouldn’t help if they suddenly said it tomorrow, since constitutionally such determiniation is purely the domain of the Executive. (And they could probably word it in such a way as to not affect the current status quo either.)