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The 3rd Circuit Court will hear today oral arguments in USA v. Safehouse, the Justice Department's effort to block a Philadelphia non-profit from opening a supervised injection site.
Audio will be live streamed here: https://www.youtube.com/c/USCourtsCA3/
Let's review how we got here. Thread.
Audio will be live streamed here: https://www.youtube.com/c/USCourtsCA3/
Let's review how we got here. Thread.
Philadelphia experienced a brutal spike in overdoes death in 2017. Fentanyl overtook the heroin supply and more than 1,200 people died representing, 34% increase from the previous year.
This horrifying level of overdose death remained ever since. https://www.phila.gov/media/20180912140436/chart-v3e1.pdf
This horrifying level of overdose death remained ever since. https://www.phila.gov/media/20180912140436/chart-v3e1.pdf
In May 2017, a task force commenced by the mayor released 18 recommendations to respond to opioid addition and overdose death in the city.
Recommendation 13: "Further explore comprehensive user engagement sites." [i.e. supervised injection sites] https://www.phila.gov/media/20180606131257/Mayors-task-force-to-combat-the-opioid-epidemic-in-Philadelphia-final-report.pdf
![In May 2017, a task force commenced by the mayor released 18 recommendations to respond to opioid addition and overdose death in the city.Recommendation 13: "Further explore comprehensive user engagement sites." [i.e. supervised injection sites] https://www.phila.gov/media/20180606131257/Mayors-task-force-to-combat-the-opioid-epidemic-in-Philadelphia-final-report.pdf](https://pbs.twimg.com/media/Em83Mj0WEAElCPe.jpg "In May 2017, a task force commenced by the mayor released 18 recommendations to respond to opioid addition and overdose death in the city.Recommendation 13: \"Further explore comprehensive user engagement sites.\" [i.e. supervised injection sites] https://www.phila.gov/media/20180606131257/Mayors-task-force-to-combat-the-opioid-epidemic-in-Philadelphia-final-report.pdf")
Recommendation 13: "Further explore comprehensive user engagement sites." [i.e. supervised injection sites] https://www.phila.gov/media/20180606131257/Mayors-task-force-to-combat-the-opioid-epidemic-in-Philadelphia-final-report.pdf
After a brutal end to the year, and as data showed that Philadelphia crossed 1,200 overdose deaths, on Jan 23, 2018, officials including health commissioner, managing director, district attorney, and police commissioner gave a thumbs up for a site to open. https://www.inquirer.com/philly/health/addiction/safe-injection-sites-overdose-deaths-opioids-philadelphia-officials-support-20180123.html
This was a very confusing moment. Most people, I think, didn't understand what was announced. The city was "allowing" a supervised injection site but promised not to operate or fund it.
Half of Philly heard: THIS IS COMING TO YOUR HOME NOW!
Others heard: WE ARE DOING NOTHING!
Half of Philly heard: THIS IS COMING TO YOUR HOME NOW!
Others heard: WE ARE DOING NOTHING!
A lot of outrage. A LOT of misinformation. Nothing changed on the ground and overdose death continued at a rate of three fatalities a day.
Fast forward to October 2018.
Former Gov. Ed Rendell, who as Philly mayor authorized the city's only syringe exchange in 92, partnered w/ two harm reduction leaders in the city to incorporate a nonprofit that will open the site - @SafehousePhilly. https://www.inquirer.com/philly/health/addiction/safe-injection-site-philadelphia-ed-rendell-prevention-point-20181002.html
Former Gov. Ed Rendell, who as Philly mayor authorized the city's only syringe exchange in 92, partnered w/ two harm reduction leaders in the city to incorporate a nonprofit that will open the site - @SafehousePhilly. https://www.inquirer.com/philly/health/addiction/safe-injection-site-philadelphia-ed-rendell-prevention-point-20181002.html
Trump appointed US Attorney, and Fox News thirst machine, William McSwain immediately vowed to drop the hammer on a supervised injection site. https://www.inquirer.com/philly/news/pennsylvania/philadelphia/u-s-attorney-vows-measures-to-stop-safe-injection-site-plan-says-he-wont-look-the-other-way-20181013.html
Again uproar. Again not much changed on the ground.
In Feb 2019, after another year in which Philadelphia lost another 1,116 people to overdose, McSwain filed a federal lawsuit in the Eastern District of Pennsylvania arguing that supervised injection sites are illegal - and should be ordered to never open. https://www.inquirer.com/news/supervised-injection-sites-philadelphia-stop-safehouse-us-attorney-opioid-crisis-20190206.html
What law does a supervised injection site violates?
According to McSwain, the Crack House Statute - federal law crafted by Sen Joe Biden that makes operating a property for the "purpose of" using drugs a felony punishable by 20 years in prison. https://www.politico.com/magazine/story/2019/05/23/joe-biden-2020-drug-war-policies-opioid-crisis-226933
According to McSwain, the Crack House Statute - federal law crafted by Sen Joe Biden that makes operating a property for the "purpose of" using drugs a felony punishable by 20 years in prison. https://www.politico.com/magazine/story/2019/05/23/joe-biden-2020-drug-war-policies-opioid-crisis-226933
Throughout 2019 both a bunch and nothing happened. There was a big Ed Rendell gaffe that a site was selected (it wasn't) that made people freak out and stuff like that.
The first court hearing was scheduled for August.
The first court hearing was scheduled for August.
In the first hearing, Judge Gerald McHugh made it clear that the point wasn't to debate the merits of a supervised injection site but to understand what the site would look like so that the law can be applied to it.
For a play-by-play of that hearing: https://twitter.com/abgutman/status/1163430319699234823
For a play-by-play of that hearing: https://twitter.com/abgutman/status/1163430319699234823
What were the types of questions that McSwain asked? These type of questions. https://twitter.com/abgutman/status/1163528288666562562
In the second hearing, in September, the point was for each side to answer the judge's questions on their legal argument.
The question boils down to: Do the activities that Safehouse described they are planning violate the language of the Crack House Statue?
The question boils down to: Do the activities that Safehouse described they are planning violate the language of the Crack House Statue?
For a play-by-play of that hearing: https://twitter.com/abgutman/status/1169644670919553024
It got very technical on the meaning of words in the statute but it was very illuminating.
It got very technical on the meaning of words in the statute but it was very illuminating.
The basic argument of McSwain is that Safehouse wants to open a property for the purpose of using drugs, as the statute prohibits.
Safehouse responded that they have "a singular purpose: save the lives of our loved ones." The drug use is incidental to the purpose.
Safehouse responded that they have "a singular purpose: save the lives of our loved ones." The drug use is incidental to the purpose.
The hearing showed the pettiness of McSwain's argument.
McSwain said he supports syringe exchanges.
Judge asked: what if exchange tells ppl to use on the sidewalk outside the door so they can respond w/ naloxone?
McSwain said that's different than a supervised injection site.
McSwain said he supports syringe exchanges.
Judge asked: what if exchange tells ppl to use on the sidewalk outside the door so they can respond w/ naloxone?
McSwain said that's different than a supervised injection site.
Another time that McSwain showed the pettiness of his argument:
judge asked if parents take in an adult child in addiction and say 'we want you to stop using drugs but if you use, use here because we have naloxone' is that a violation of the crack house statute?
McSwain: No.
judge asked if parents take in an adult child in addiction and say 'we want you to stop using drugs but if you use, use here because we have naloxone' is that a violation of the crack house statute?
McSwain: No.
On October 2nd, Judge McHugh ruled that a supervised injection site DOES NOT violate federal law.
"By any objective measure, what Safehouse proposes is not some variation on a theme of drug trafficking.. even if one believes it to be misguided.. not prototypically criminal."
"By any objective measure, what Safehouse proposes is not some variation on a theme of drug trafficking.. even if one believes it to be misguided.. not prototypically criminal."
Judge ruled so it's all done right? No.
Immediately after the ruling McSwain promised to "use all enforcement tools" to shut down a site if Safehouse opens before the appeal.
A peach right? https://www.inquirer.com/health/opioid-addiction/supervised-injection-site-philly-safehouse-appeal-mcswain-mchugh-goldfein-20191015.html
Immediately after the ruling McSwain promised to "use all enforcement tools" to shut down a site if Safehouse opens before the appeal.
A peach right? https://www.inquirer.com/health/opioid-addiction/supervised-injection-site-philly-safehouse-appeal-mcswain-mchugh-goldfein-20191015.html
January 2020. Three months after the ruling in favor of Safehouse. Another months ends with another 1,200 people dying of overdose in Philadelphia.
Safehouse asks Judge McHugh to issue a final order -- allow them to open during appeal. https://www.inquirer.com/health/opioid-addiction/safe-injection-site-philly-opening-appeal-safehouse-mcswain-goldfein-20200107.html
Safehouse asks Judge McHugh to issue a final order -- allow them to open during appeal. https://www.inquirer.com/health/opioid-addiction/safe-injection-site-philly-opening-appeal-safehouse-mcswain-goldfein-20200107.html
Things started to look real. Philadelphia started to work on a public safety plan for a supervised injection site. https://www.inquirer.com/health/opioid-addiction/supervised-injection-site-philadelphia-public-safety-plan-20200221.html
In February 25th, 2020, Judge McHugh signed a final order allowing Safehouse to open a supervised injection site while the appeal goes on.
"there is nothing procedurally improper in granting the declaratory relief sought by Safehouse."
"there is nothing procedurally improper in granting the declaratory relief sought by Safehouse."
Hours after the final order, Safehouse announced that a the nation's first legally authorized supervised injection site will open in South Philadelphia within a week.
ALL HELL BROKE LOSS. https://www.inquirer.com/news/philadelphia-supervised-injection-site-opening-federal-ruling-20200225.html
ALL HELL BROKE LOSS. https://www.inquirer.com/news/philadelphia-supervised-injection-site-opening-federal-ruling-20200225.html
Outreage. NIMBYism. Grandstanding from state and local officials. Fast tracking of zoning bill in City Council to define a supervised injection site a nuisance and a State bill to require community support (not defined).
The plan collapsed very quickly.
https://www.inquirer.com/news/supervised-injection-site-safehouse-south-philadelphia-protest-20200228.html
The plan collapsed very quickly.
https://www.inquirer.com/news/supervised-injection-site-safehouse-south-philadelphia-protest-20200228.html
A couple of weeks after the final order from the judge and the South Philly saga, the coronavirus pandemic hit.
A few months after, George Floyd was murdered by police.
In June, McHugh told Safehouse not to open a site because the city was too "frayed." https://www.inquirer.com/health/opioid-addiction/safe-injection-site-legal-philly-safehouse-mcswain-mchugh-appeal-third-circuit-20200624.html
A few months after, George Floyd was murdered by police.
In June, McHugh told Safehouse not to open a site because the city was too "frayed." https://www.inquirer.com/health/opioid-addiction/safe-injection-site-legal-philly-safehouse-mcswain-mchugh-appeal-third-circuit-20200624.html
That ruling was upsetting for many, including me, but arguably it was overall positive for the legal case.
Judge McHugh added a TON of evidence in support of supervised injection sites to the public record -- and demolished BS arguments. https://www.safehousephilly.org/sites/default/files/attachments/2020-06/156_OpGrStay%20e062420.pdf
Judge McHugh added a TON of evidence in support of supervised injection sites to the public record -- and demolished BS arguments. https://www.safehousephilly.org/sites/default/files/attachments/2020-06/156_OpGrStay%20e062420.pdf
That's overall where we are. Philadelphia probably lost more than 3,500 people to overdose death since the green light announcement in Jan 2018.
The oral argument in the Third Circuit are starting now in front of the 3 panel judge. I'll live tweet.
The oral argument in the Third Circuit are starting now in front of the 3 panel judge. I'll live tweet.
Trump appointed prosecutor William McSwain starts. He says the big idea in the district court's ruling was that because lawmakers in 1986 didn't think of supervised injection sites when they wrote the Crack House Statute, Safehouse isn't violates the law. He says that's wrong.
McSwain says the this big idea doesn't matter. The recent precedent in SCOTUS case of Bostock v Clayton from June reminds that judicial review should look at the wording of the law. https://www.supremecourt.gov/opinions/19pdf/17-1618_hfci.pdf
Judges test the limit of that argument with hypotheticals.
Judges test the limit of that argument with hypotheticals.
Judge: Crack House Statute talks about "*THE* purpose" and not "*a* purpose." So should we look at Safehouse as a whole or just on the consumption room?
McSwain: the defining characteristic of Safehouse, unlike Prevention Point, is the consumption room.
McSwain: the defining characteristic of Safehouse, unlike Prevention Point, is the consumption room.
Judge Roth: "When you are assuming that we agree with you on 'purpose of' I would forewarn you that I don't at all."
McSwain: would you agree that the purpose of stone cold crack dealer (deliberate choice of drug) is to make money?
McSwain: would you agree that the purpose of stone cold crack dealer (deliberate choice of drug) is to make money?
Judge Roth: "where in the Controlled Substance Act does it say that it is unlawful to use?"
silence.
silence.
Judge: does unlawfully include violations of state law?
McSwain: we are talking about federal law
Judge: why not add that?
McSwain: I would not foreclose it if court thinks it's important but I don't think it's necessary
(note to self: come back to what behind this exchange)
McSwain: we are talking about federal law
Judge: why not add that?
McSwain: I would not foreclose it if court thinks it's important but I don't think it's necessary
(note to self: come back to what behind this exchange)
"Let's assume you need to prove the first party's purpose (Safehouse) and not the third party's purpose (the person using in the site)"
McSwain: There is a necessary pre-condition of using drugs... in Safehouse (for their services)
McSwain: There is a necessary pre-condition of using drugs... in Safehouse (for their services)
This feels very funny to me for McSwain to make this argument. By framing drug use as a "pre-condition" didn't he just give safehouse the W: the purpose of safehouse is to save lives and the pre-condition for that is drug use, i.e. incidental to the purpose.
YES FINALLY THIS QUESTION
Judge: What if a strip mall gives a storefront for a medical marijuana store would that violate the crack house statute?
McSwain: practically we can't because Congress tells us not to in appropriation
That's the answer McSwain gave me in the past.
Judge: What if a strip mall gives a storefront for a medical marijuana store would that violate the crack house statute?
McSwain: practically we can't because Congress tells us not to in appropriation
That's the answer McSwain gave me in the past.
Judge: If a bank gives a mortgage to a person who uses the house for someone who then sells drugs from the house, can the bank be prosecuted under crack house statute?
McSwain: if they knew that purpose, yes.
McSwain: if they knew that purpose, yes.
A lot of this is technical about the first and second subsections of the "unlawful acts" in the crack house statute.
McSwain says (a)(1) is about owner of the property also engaging in drug activity while (a)(2) is about drug activity of third party (so relevant to safehouse).
McSwain says (a)(1) is about owner of the property also engaging in drug activity while (a)(2) is about drug activity of third party (so relevant to safehouse).
McSwain says even if you do look at legislative history, the goal of Crack House Statute was to give remedy to nuisance properties. The "revolt" of South Philly and actions of City Council members grandstanding are the proof for McSwain that sites meet the meaning of the law.
Interesting hypothetical from the judge: If a medical facility allows people to use drugs while they transition to something like methadone, would that facility be liable under (a)(2)?
McSwain says yes & that's why they don't exist.
That's everything wrong with US drug policy.
McSwain says yes & that's why they don't exist.
That's everything wrong with US drug policy.
FASCINATING hypothetical.
Judge: If a partner in a law firm uses cocaine. Everyone knows. Can the firm be held liable under the crack house statute?
McSwain: No because he presumably still acts as a lawyer.
Race + class and War on Drugs example *chef's kiss*
Judge: If a partner in a law firm uses cocaine. Everyone knows. Can the firm be held liable under the crack house statute?
McSwain: No because he presumably still acts as a lawyer.
Race + class and War on Drugs example *chef's kiss*
McSwain to me should have lost when he said that parents telling a kid who isn't living with them to come and use in their place *wouldn't* be liable under Crack House Statute even if they bring a friend, though it gets closer.
So basically now the argument is that McSwain keeps coming back to a new (made up) legal criteria: "concentrated drug activity." Judge say that's nowhere in the law.
A discussion about a RV. McSwain says mobile anything is not covered under the law (he said that also in district court). Judge asks why is it not under the literal interpretation of the law. "Our position... to be talking about real estate."
EVERYONE QUICK OPEN MOBILE SUPERVISED INJECTION SITES MCSWAIN SAYS IT'S ALL GRAVY
Always good to say to judges: Maybe this is something I haven't thought about enough.
"I don't think you can be cute and go around the statute and load your RV with heroin"
1. No one is loading anything with heroin.
2. He keeps coming back to a single concentrated location.
"I don't think you can be cute and go around the statute and load your RV with heroin"
1. No one is loading anything with heroin.
2. He keeps coming back to a single concentrated location.
"It's not a perfect statute... if vans started popping everywhere that is something [that we will need to address, maybe Congress]."
McSwain says we should focus on the wording on the law and not legislative history.
Also keeps coming back to "location" and "concentrated" drug activity. So just checking the wording of the law.
Also keeps coming back to "location" and "concentrated" drug activity. So just checking the wording of the law.
Moving to constitutional issues: Is there any commerce clause violation here?
Judge: is the fact that Safehouse's service is free makes it "economic activity"?
McSwain: Safehouse is going to have an effect on interstate commerce because it will effect the market for drugs.
Judge: is the fact that Safehouse's service is free makes it "economic activity"?
McSwain: Safehouse is going to have an effect on interstate commerce because it will effect the market for drugs.
I don't get why McSwain keeps brining back marijuana. Safehouse is not a dispensary. There is no sale. The impact on the drug market is *very* convoluted, interesting, but not at all clear.
Did the judge just told McSwain that his interpretation of (a)(1) and (a)(2) is "ass backwards"?
Not important but McSwain randomly mentioned that heroin is more expensive than marijuana. Lol prosecutors really don't know anything about drugs.
McSwain is done. He will have 5 minutes to respond at the end. Now is Ilana Eisenstein for Safehouse. Starts by saying that the purpose of Safehouse is saving lives.
We are back to "whose purpose under (a)(1) and (a)(2)?"
Again the question is whether the person who owns the property is the person who engages in illegal drug activity. In (a)(1) both agree it's the same person. The meaning of "purpose" in (a)(2) is the question.
Again the question is whether the person who owns the property is the person who engages in illegal drug activity. In (a)(1) both agree it's the same person. The meaning of "purpose" in (a)(2) is the question.
Eisenstein for Safehouse says the statute is about a property and the owner of the property, not the action of visitors.
Eisenstein says that McSwain is wrong when he says that the necessary pre-condition for Safehouse is consumption. "The necessary pre-condition for Safehouse's existence is the overdose crisis."
Judge: You are saying our real purpose is to prevent overdose... but also your purpose is for people to use there.. you are giving the syringes... how is the drug use incidental? (judge says it's not like syringes for a diabetic but to shoot up heroin)
Eisenstein responds that the diabetes response is good. Congress recognizes that addiction a disease. You wouldn't say that someone gives syringes for the purpose of the diabetes but to treat the diabetes. The goal of Safehouse is to treat the after effects of consumption.
Under the current model, in syringe exchanges, a person is given the syringe and then forced to leave in the moment that they are most at risk.
Reminds that the defining characteristic of addiction is use *despite* harmful consequences. That's where Safehouse comes in.
Reminds that the defining characteristic of addiction is use *despite* harmful consequences. That's where Safehouse comes in.
Back to (a)(2) and the role of third party. Now talking about the phrase "making available for use." Judge says it shows Congress contemplated a third party using. But Eisenstein says that at no point anyone except for Safehouse will have *use* of property.
Judge: according to your reading of (a)(2) it's really hard to come up with a violation of (a)(2) that isn't already covered by (a)(1)? (Congress shouldn't add meaningless statements to the law, "surplusage")
Eisenstein gives various examples on landlords
Eisenstein gives various examples on landlords
Judge won't let go. Why isn't that covered by "lease" or "rent" in (a)(1)? Why did Congress add (a)(2)?
Eisenstein eventually lands on a hypothetical of informal arrangement (boyfriend at work know girlfriend sells drugs from the apartment).
Eisenstein eventually lands on a hypothetical of informal arrangement (boyfriend at work know girlfriend sells drugs from the apartment).
Judge: Is there any criminal statute that takes into account the motive of a third party in the prosecution?
Eisenstein: I know of known.
Other judge brings up Pinkerton liability, on how co-conspirators are prosecuted.
Eisenstein: Not the same.
(Legally above my head)
Eisenstein: I know of known.
Other judge brings up Pinkerton liability, on how co-conspirators are prosecuted.
Eisenstein: Not the same.
(Legally above my head)
Eisenstein brings examples of past prosecution of Crack House Statute. Shows that most cases were about profiting from drug activity. Says we need to think of a high threshold to move from a possession misdemeanor to a felony punished with 20 years.
Listening to this is a reminder why we should never try to read tea leaves with judges. They always sound against who they are currently questioning.
Eisenstein: "People are coming to Safehouse because they don't want to die... Mr. McSwain keeps talking about heroin but [most of the supply in the city] is fentanyl."
Judge: "The point is that you are right, lives may be saved. There is a real wonderful motive here. But we are stuck with the words of the statue."
Eisenstein says she agrees that benevolent motive is insufficient. But motive and purpose are different. Says Crack House Statute is fairly narrow statute. The purpose of Safehouse is not drug activity.
Now judges are drilling down on the word "intentionally" in (a)(2)?
Eisenstein: I think it's a question about specific intent and our purpose.
Eisenstein: I think it's a question about specific intent and our purpose.
Eisenstein makes a helpful analogy on "make available for use." She says the use is not of drugs but of the place. It's about relinquishing control of the place. For example: a hospital giving OR admitting privileges makes the OR "available for use."
Judge asks Eisenstein why not just see the simplest interpretation of available for use -- making the space available of use of drugs. Eisenstein responds that if that was the case, McSwain's response to hypothetical of parent and kid should have been different.
We are back to the commerce clause question. Is Safehouse going to impact interstate commerce?
Eisenstein says that because Safehouse is not doing anything more than what's already legal elsewhere (syringes, naloxone) then no significant impact. https://twitter.com/LeoBeletsky/status/1328371598953390080
Eisenstein says that because Safehouse is not doing anything more than what's already legal elsewhere (syringes, naloxone) then no significant impact. https://twitter.com/LeoBeletsky/status/1328371598953390080
Side bar: the questions about the underlying drug law shows that we MUST rewrite our drug laws from scratch. Ridiculous and at the same time, somehow, broad and all encompassing and super narrow.
I'll be honest with you, this commerce clause discussion is a bit above my head in terms of figuring out what they are getting at. Damn I should have gone to law school.
Judge (I think Bibas) says that getting too much into motive into the realm of policy.
Eisenstein: how are you going to stop the government from prosecuting parents helping children? homeless shelter providers that practice HUD's policy of housing first?
Eisenstein: how are you going to stop the government from prosecuting parents helping children? homeless shelter providers that practice HUD's policy of housing first?
Eisenstein says that when it comes to simple possession, courts took motives seriously. Cites rulings (including DC Circuit) that says Crack House Statute isn't about simple possession.
Says, McSwain wants you to focus on the user but you should focus on the operator.
Says, McSwain wants you to focus on the user but you should focus on the operator.
I found this compelling. Eisenstein says that other people might use motive to say that they didn't commit a drug crime. But that happens in criminal law already ALL THE TIME and that's why there is review of evidence. And the evidence shows in Safehouse that that's not the case.
"If we had a facility with room for only one person, we would do it because saving one life is worth it."
Eisenstein responds to McSwain threshold and concentrated drug activity arguments.
Eisenstein responds to McSwain threshold and concentrated drug activity arguments.
McSwain gets 5 minutes rebuttal.
McSwain: Safehouse are making policy argument.. they talk about the need of overdose prevention... I don't disagree with any of that... we are on the same side.. we try to do everything we can to save people's lives. But it has to be done within the bounds of the law.
McSwain: does a third party's intent matter in criminal prosecution? Yes. Think about conspiracy. It's about the meeting of minds.
Then says that it also comes in economic and sexual crimes. For example, consent is third party state of mind making an act a crime.
Then says that it also comes in economic and sexual crimes. For example, consent is third party state of mind making an act a crime.
McSwain on intent: they intentionally make "available for use" of drug policy.
Last point: The hypotheticals are interesting but "that's not this case." It's not a hypothetical. "Safehouse is inviting scores of people to one place."
Last point: The hypotheticals are interesting but "that's not this case." It's not a hypothetical. "Safehouse is inviting scores of people to one place."
Judge asks the government to pick up the cost of the transcript. Tells both counselors that they did a good job.
We are done.
Now we wait.
We are done.
Now we wait.
I have no idea how this is going to go. I think it's impossible to guess. I would also imagine that either way this goes all the way to the Supreme Court regardless to the 3rd Circuits ruling -- unless Biden's AG does the right thing and not fight appeal or appeal. /fin
