[2404.HQ] Constitutionality of the Resolution to Restore Regional Accountability

High Court
1

Your honors,

I come to you today to submit a Legal Question as per Article 4 of the Judicial Act (“JA”). As a current member of the South Pacific, I have standing to submit such a question in accordance with JA 4.2.

My question is: Does the Resolution to Restore Regional Accountability (“RtRRA”) function as a Bill of Attainder, which makes it unlawful as per Article III.2 of the Charter?

My interpretation follows.

RtRRA indeed is blatantly unlawful and unconstitutional, and the only possible remedy is for the Court to declare it null and void in its entirety. RtRRA 1.3 states:

(3) The Assembly hereby repeals Section B, sub-section 2 of the Assembly Resolution to Restore the Coalition of the South Pacific .

The referenced Assembly Resolution to Restore the Coalition of the South Pacific (“ARtRC”) was passed on February 9, 2016 (see Assembly Resolution on the Restoration of the Coalition of the South Pacific (tspforums.xyz)). Over 3 months later, on May 26, 2016, the Continuing Resolution of the Great Council of 2016 (Great Council 2016 Continuing Resolution (tspforums.xyz)) declared it without legal force (which RtRRA, ironically, states within itself). Therefore, amending ARtRC is obviously not possible in the first place and therefore unlawful.

The relevant sub-section of ARtRC states:

  1. All individuals involved in the forum move and the Transitional Government will receive a general amnesty for their actions, conditional on good behaviour and acknowledgement of culpability, and revocable by the Assembly at any time during the next six months.

Let us assume a hypothetical member called Cheesepickles who was a member of the above-mentioned Transitional Government, showed good behavior after the coup, and acknowledged their culpability on or before May 26, 2016. That means, by the time ARtRC lost its legal force, the amnesty it granted had already been applied and was valid. An amnesty means that legally, an action has been forgotten and therefore the actions of the coup cannot be used against Cheesepickles.

RtRRA 1.4 states, in part:

(4) Those who […] are responsible for their statements, actions, or omissions leading up to and during the 2016 coup d’état.

For Cheesepickles, this would mean that the acts that had been legally forgotten would now be unforgotten by an act of the Assembly 8 years later. This is nothing else than a bill of attainder against Cheesepickles, which is blatantly and obviously illegal as per Charter III.3.

RtRRA’s marking as constitutional law does not make a difference in this case, as it violates the Charter itself which takes precedence over constitutional law, as decided in HCLQ1803.

I would write more, but this is such a blatant and obvious violation of the Charter, and the most egregious by far that I can remember in my time in the South Pacific, that I am at a loss for words. I am happy to answer your questions and to explain this most obvious of interpretations in more detail.

With kind regards,
– Roavin

2
High Court of the South Pacific

Notice of Reception

Let this serve as notice that this petition has been received by the High Court and has been assigned the following identifying information:

Docket Number
2404.HQ

Reference Name
Constitutionality of the Resolution to Restore Regional Accountability

Request
Does the Resolution to Restore Regional Accountability (“RtRRA”) function as a Bill of Attainder, which makes it unlawful as per Article III.2 of the Charter?

Submission: 18 July 2024

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3
High Court of the South Pacific

[2404.HQ] Constitutionality of the Resolution to Restore Regional Accountability

Whereas this Court has been asked to exercise the judicial power vested in it by Article VII of the Charter of the South Pacific, it is resolved that this case is justiciable and will be considered for resolution by a panel of two justices.

Associate Justice @Pronoun has been assigned as the primary Justice for this case, with Associate Justice @Griffindor as the secondary Justice.

The petitioner and interested parties may submit arguments with their views on this case no later than 2024-07-27T00:00:00Z, but the Court reserves the right to issue an opinion before then.

Submission: 18 July 2023 | Determination: 19 July 2023

4

Your honours, I respectfully request the Court for leave to file an amicus brief in opposition to the petitioner’s argument.

5

So noted. The Court would, however, request an approximate estimate when possible as to the length of time needed for such leave beyond the time allotted above.

6

I do not expect to require time beyond the timeframe provided by the Court.

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7

Your Honors,

I also plan to file an amicus brief in this case. It will be submitted as soon as possible, and in any event within the Court’s announced deadline.

8

Your honors,

I must submit a slight correction of my original question, because it was rooted on a misunderstanding of what “bill of attainder” means. However, the underlying premise of the question remains valid - does RtRRA violate III.2 of the Charter?

OOC: I don’t do law IRL, briefly looked up “bill of attainder” while staring at III.3 which also had the ex post facto item and thought a bill of attainder is just a form of an ex post facto law and didn’t consider that the meaning from the Charter specifically refers to a bill that already contains verdict and sentence. After some discussion on Discord, I looked it up again, with a bit more care this time, and specifically at the US interpretation of the phrase since the Charter’s Section III is written by somebody familiar with, and inspired by, corresponding US law.

My interpretation is simple: RtRRA 1.4 explicitly states that “those” (which includes TGSP members) are now “responsible” for their actions, which means that those that had amnesty granted to them should no longer have that protection. This isn’t just my interpretation, I explicitly asked RtRRA’s author on Discord:

[4:59 PM] Roavin: Repeal the amnesty, as in, those that had amnesty granted to them no longer do?
[5:20 PM] Kringle: That’s what repeal means.

By recriminalizing those acts which had been explicitly legally forgiven/forgotten, RtRRA functions as an ex post facto law and is therefore unequivocally a violation of Charter III.2.

It really is as simple as that.

9

Your honor and may it please the Court,

I wish to enter the below as an interested party, by virtue of being a citizen of the Coalition who was impacted by the contextual subject matter of the Resolution to Restore Regional Accountability. I limit my response to the question asked: Does the Resolution to Restore Regional Accountability (“RtRRA”) function as a Bill of Attainder, which makes it unlawful as per Article III.2 of the Charter? If the Court alters the scope of their question, I request an extension provided for interested parties to prepare briefs in response to the new question.

The answer to this is a resounding “No.” A bill of attainder is defined by the LLI Wex Library as:

“… [A] piece of legislation that declares a party is guilty of a crime. Bills of attainder allow the government to punish a party for a perceived crime without first going through the trial process.”

The RtRRA fails to meet this definition because it doesn’t inflict a punishment on any individual. It repeals an amnesty given in 2016, but does not declare any person guilty of a crime nor sentence them a punishment. The only action the resolution takes on individuals is to declare that they “are responsible for their statements, actions, or omissions[.]” That’s a statement of reality, not a conviction without trial.

Any individuals who belonged to the Cabinet in section 4 of the resolution are no more convicted of a crime today than they were after the grant of amnesty. Whether or not these individuals, to the extent that any are still citizens of the Coalition, could have charges brought against them doesn’t alter the nature of the resolution. To be a bill of attainder, the resolution must have declared specific individuals guilty of a crime and inflicted a punishment without trial. It plainly doesn’t do that. The state of being subject to criminal law isn’t itself a conviction or punishment, otherwise the mere existence of criminal law would be inflicting punishment on everybody.

Thank you.

10

Your Honors,

While I am pleased that Roavin has come to agree that the Resolution does not constitute a Bill of Attainder, I would urge the Court to nevertheless answer the question originally presented in this case. For two reasons. First, my research on this Court’s case law indicates that it has never interpreted the Charter’s Bill of Attainder clause. It would be valuable to have regional precedent on this important feature of our constitutional law. Indeed, clarifying such questions is precisely the purpose of the legal question mechanism. Second, the Court has thus far found only the original question presented to be justiciable, so it’s decision in this case should be limited accordingly. Of course, Roavin is free to submit a separate legal question on whether the Resolution operates as an ex post facto law, which I believe would be the more appropriate procedural path for addressing that issue.

With that said, my below brief is limited to the Bill of Attainder question. I will prepare a separate brief on the ex post facto issue should it be necessary in this or, preferably, a separate and subsequent case.

The Resolution to Restore Regional Accountability is consistent with the Charter. On the petitioner’s (now abandoned) account, the Resolution “functions as a Bill of Attainder” and is therefore “blatantly unlawful and unconstitutional,” such that “the only possible remedy is for the Court to declare it null and void in its entirety.” That is wrong. The Resolution bears no relationship to a Bill of Attainder: It does not determine guilt, it does not impose punishment, and it does not alter the ironclad constitutional guarantee that to do either is the exclusive province of this Court.

The lynchpin question in this case—what constitutes a “Bill of Attainder”—is not a difficult one. To be sure, the Charter does not expressly define that term: It simply provides that “[n]o member may be subject to any bill of attainder.” Charter III.(2). But the lack of a separate definition is not particularly surprising. “Bill of Attainder” is not a novel concept unique to our Charter; rather, it was a preexisting legal term of art with deep roots in the common law. Those who framed the Charter plucked the term from that context and adopted it as part of our law. And when “a word is obviously transplanted from another legal source, whether the common law or other legislation, it brings the old soil with it.” Frankfurter, Some Reflections on the Reading of Statutes, 47 Colum. L. Rev. 527, 537 (1947). Put differently, there was no need to define “Bill of Attainder,” as the Charter simply incorporated the well-established meaning of that term. Since this Court has never issued an opinion interpreting the Bill of Attainder clause, it is appropriate to consult external sources to ascertain that meaning.

A Bill of Attainder has four key features. It is “a law that [1] legislatively determines guilt and [2] inflicts punishment [3] upon an identifiable individual [4] without provision of the protections of a judicial trial.” Nixon v. Adm’r of Gen. Servs., 433 U.S. 425, 468 (1977). One can trace these fundamental elements back to the fourteenth century, but, for the sake of the Court’s time, I will stop at the eighteenth. See Caplan, Nonattainder as a Liberty Interest, 2010 Wisc. L. Rev. 1203, 1211 (“A bill of attainder is a law imposing punishment on identified individuals without judicial trial.”); United States v. Lovett, 328 U.S. 303, 315 (1946) (defining Bills of Attainder as “legislative acts, no matter what their form, that apply either to named individuals or to easily ascertainable members of a group in such a way as to inflict punishment on them without a judicial trial.”); Cummings v. Missouri, 71 U.S. (4 Wall.) 277, 323 (1867) (“A bill of attainder is a legislative act which inflicts punishment without a judicial trial . . . [T]he legislative body . . . pronounces upon the guilt of the party, without any of the forms or safeguards of trial”); Story, Commentaries on the Constitution § 1338 (1833) (“In bill of attainder cases, the legislature assumes judicial magistracy, pronouncing upon the guilt of the party without any of the common forms and guards of trial”); Calder v. Bull, 3 U.S. (3 Dall.) 386, 389 (1798) (opinion of Chase, J.); see also United States v. Brown, 381 U.S. 437, 442 (1965) (describing an analogous constitutional provision prohibiting Bills of Attainder as a “safeguard against legislative exercise of the judicial function, or more simply—trial by legislature.”).

As should now be clear, the Resolution shares almost none of the defining characteristics of a Bill of Attainder. To illustrate the point, consider Cheesepickles. The plight of this hypothetical coup plotter features prominently in the petitioner’s argument. But what is their plight? Consider: Did the Resolution determine that Cheesepickles was guilty of anything? No. Did the Resolution impose any form of punishment on Cheesepickles? No. Did the resolution deprive Cheesepickles of their right to judicial process before being found guilty or punished? No. Did the Resolution subject Cheesepickles to trial by legislature? Again, no. The solitary effect of the Resolution is to repeal the Amnesty. That’s it. Cheesepickles remains legally innocent, and, if anyone were to bring criminal charges against them in the future, they would enjoy the full panoply of procedural protections associated with trial before this Court, including a presumption of innocence, the right to present evidence, and the right challenge the constitutionality of the prosecution. All they would be prevented from doing is raising the Amnesty as a defense for their past conduct. Thus, however one might describe Cheesepickles’ plight, they plainly have not been subjected to a Bill of Attainder.

For the foregoing reasons, this Court should hold that the Resolution does not constitute a Bill of Attainder and is therefore constitutional.

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11

Your honors,

Given my mistake in the initial submission, would you prefer a new Question or would you prefer this one to be amended? The Judicial Act does not prescribe or prohibit either.

12
High Court of the South Pacific

[2404.HQ] Constitutionality of the Resolution to Restore Regional Accountability

The Court gives notice that:

  1. The Court intends to limit the scope of its ruling in this case (2404.HQ) to answering the legal question as originally submitted and determined to be justiciable.
  2. Petitioner or any other member of the South Pacific is welcome to submit other legal questions, including on matters potentially related to this case, in accordance with typical operations of the Court.
  3. To the Court’s understanding, Petitioner has not requested withdrawal or dismissal of this case. Petitioner is welcome to clarify this understanding if this understanding is incorrect.

Submission: 18 July 2023 | Determination: 19 July 2023

13

Your honors,

I agree with Welly’s assessment that an interpretation of the bill of attainder section would be useful, and will submit a separate case with my corrected question.

14
High Court of the South Pacific

[2404.HQ] Constitutionality of the Resolution to Restore Regional Accountability

Petition
Does the Resolution to Restore Regional Accountability (“RtRRA”) function as a Bill of Attainder, which makes it unlawful as per Article III.2 of the Charter?

Summary of the Ruling
It is the opinion of the Court that the Resolution to Restore Regional Accountability does not operate as a bill of attainder. A bill of attainder, as members of the Coalition are shielded from by Charter III(2), is a law that (1) targets a member of the South Pacific or a definite and finite group of members of the South Pacific; (2) names, or makes easily identifiable, the member(s) being targeted; and (3) either (i) declares the targeted member(s) to be guilty of a crime or (ii) imposes, among its primary intents and effects, criminal punishment. The Resolution to Restore Regional Accountability neither legislatively declares guilt nor imposes punishment.

Justice Pronoun delivered the ruling, signed also by Justice Griffindor.

I

In February 2016, the Assembly adopted the Assembly Resolution to Restore the Coalition of the South Pacific (the 2016 Resolution), which, in relevant part, stipulated that “[a]ll individuals involved in the forum move and the Transitional Government” preceding the resolution “will receive a general amnesty for their actions.”1 In March 2024, the Assembly adopted the Resolution to Restore Regional Accountability, repealing the aforementioned section of the 2016 Resolution and re-establishing the responsibility of certain individuals involved in “the forum move and the Transitional Government” for their actions. The question before the Court is whether, by doing so, the Resolution to Restore Regional Accountability operates as a bill of attainder.

II

Members of the Coalition are afforded protection from bills of attainder by Article III, Section 2 of the Charter, under which “[n]o member may be subject to any bill of attainder.”2 The established meaning of the term ‘bill of attainder,’ the context of the protection against bills of attainder within regional law, and the legislative history of bills of attainder in the South Pacific all support a single, consistent understanding of this protection. A bill of attainder is a law that: (1) targets a member of the South Pacific or a definite and finite group of members of the South Pacific; (2) names, or makes easily identifiable, the member(s) being targeted; and (3) either (i) declares the targeted member(s) to be guilty of a crime or (ii) imposes, among its primary intents and effects, criminal punishment.

A

The term ‘bill of attainder’ is hardly unique to the laws of the Coalition. Our laws use all manner of words in the English language without defining each and every word, just as any English speaker would. Naturally, when the law uses a term, it implicitly adopts the generally understood meaning of that term. The corpus of regional law does not define the meaning of ‘majority’ or ‘precedence’ or ‘individual’ because it does not need to; the meanings of those terms are readily understood by English speakers. Similarly, when the Assembly uses an existing legal term of art such as ‘bill of attainder,’ it naturally adopts the existing meaning of the term.

The history of bills of attainder is rooted in English law. Dating back to at least the 14th century, bills of attainder enabled Parliament to enact legislative findings of criminal guilt and to authorize death, among other consequences, as punishment. By contrast, similar legislative acts that stopped short of imposing the death sentence were known as bills of pains and penalties.3,4 Needless to say, death as a criminal punishment is well outside the scope of the laws of the Coalition. Instead, the Charter’s prohibition of bills of attainder should be construed more broadly so as not to depend on imposition of the death penalty, in much the same way that bills of attainder have been more expansively defined in a range of real-world common law jurisdictions. Institutions in countries like the United States,5 Canada,6 Australia,7 and the Philippines8 have either construed bills of attainder more broadly so as to include bills of pains and penalties or have held both categories of laws to similar standards of legal validity. Many of these courts have, borrowing language from the Supreme Court of the United States and using notably similar language, defined a bill of attainder as a legislative act “which inflicts punishment […] without a judicial trial.”9,10,11

These holdings make it clear that protections against bills of attainder have been broadly and consistently understood as protections against legislative circumvention of judicial trials. In other words, these protections shield citizens from “trial by legislature,”12 and therefore, logically, from legislation that summarily inflicts effects that fall within the province of judicial trial — namely findings of criminal guilt and impositions of criminal punishment.

B

Just as the protection against bills of attainder should be understood within the context of accepted usage of the term, so too does its context within regional law illuminate its meaning. The Charter does not refer to bills of attainder in isolation, but rather within an enumerated list of protections contained in Article III, Section 2, which protects “[t]he right to a fair trial and defense against criminal accusations.”13 These specifically enumerated protections, on a plain reading, are included within this section precisely because they serve to protect the broader right to a fair criminal trial and defense. In guarding against bills of attainder, then, the Charter seeks to prohibit a specific means by which the legislature could infringe upon Article III rights.

A necessary inference from this understanding is that bills of attainder must “apply either to named individuals or to easily ascertainable members of a group.”14 A law that does not specifically target one or more members is not a bill of attainder; any law that defines a crime will, by its very nature, target those individuals who commit the crime, and were it not for laws criminalizing certain actions, there would be no need for criminal trials in the first place. For a law to be adjudged a bill of attainder, it must target one or more members with specificity; that is, bills of attainder are characterized by targeting definite and finite individuals or groups such as by naming the targeted members explicitly, rather than targeting nebulous and indefinite groups such as ‘all individuals who misuse public office.’

A plain reading also necessitates the inference that bills of attainder declare criminal guilt or impose criminal punishment, which are the consequences of the judicial trials that the Charter protects. Criminal sentences, however, encompass a wide range of plausible penalties. For all crimes other than treason and conduct violations, the Criminal Code merely requires that punishments be proportionate to the crime,15 meaning that the sentences imposed need not be generally, historically, or typically considered to be punitive. Given this breadth, punishment can not be practically bounded within any finite set of penalties. Rather, punitive laws are highlighted by their legislative purposes, or lack thereof, as illuminated through functional and motivational tests. While these considerations are well-adopted in the real world,16 they also follow from common-sense statutory interpretation.

A functional test plainly reveals laws that have no legitimate non-punitive purposes. Laws can further legitimate legislative, regulatory, policy, or other non-punitive interests, but simple logic would indicate that if a law serves no such non-punitive purposes, then “it is reasonable to conclude that punishment of individuals disadvantaged by the enactment was the purpose of the decisionmakers.”17 A motivational test, meanwhile, reveals laws which the legislature record indicates are intended as punishment. Certainly, if the Assembly intends a law to be punishment for a perceived crime, then that law seeks to bypass judicial trial and clearly falls within established understandings of bills of attainder.

C

The Charter has not always sheltered members of the Coalition from trial by legislature. Its current protections were proposed18 and adopted19 in the Great Council of 2016 with neither discussion about nor opposition to their introduction, and Article III, Section 2 has not been amended since then. These protections, however, were a novel addition to the constitutional rights of South Pacificans. The Charter as it existed prior to the 2016 Great Council made no reference to bills of attainder.20 Neither did previous versions of the Charter from 2012,21 2010,22 2008,23, 200724 or 2006;25 after all, the Assembly only added a bill of rights in the Charter in 2013.26

In 2012, four bills of attainder were proposed in the Assembly in 2012,27,28,29,30 although two were intended as jokes.31 While the legislative history is sparse, these proposals do corroborate other understandings of bills of attainder. Each proposal identified a specific target, listed a range of grievances, and imposed a clear punishment of banishment from the region and its forums. Given that the Assembly did not refer to these bills when adopting the current bill of attainder protections, it is unclear how influential they were in drafting the Charter. Nevertheless, their structure closely mirrors other understandings of bills of attainder based on their established meaning and on existing regional law, lending further credence that those interpretive approaches comport well with bills of attainder as historically understood and debated by the Assembly.

III

In light of this definition, the Resolution to Restore Regional Accountability is not a bill of attainder. The Resolution does not declare any member of the South Pacific to be guilty of a crime, nor does it impose punishment.

While Article 1, Section 1 of the Resolution uses the term ‘unlawfully,’ this terminology should not be construed to indicate criminality. The body of regional law reaches well beyond the confines of criminal law, and not all actions that contradict regional law are criminal. Instead, the Resolution’s reference to unlawful conduct should be understood using the plain meaning of the term — which Merriam-Webster defines as “not lawful” or “illegal,”32 which is to say, “not according to or authorized by law”33 — and cannot be understood as a declaration of criminal guilt.

Article 1, Section 4 of the Resolution certainly targets a definite and finite group of individuals — namely “senior or junior members of the Cabinet at any point during the term that began on 01 December 2015 and ended on 09 February 2016, as such offices were defined in the Charter as it was written at the time of the 2016 coup d’état, as well as any other individual who actively supported the same”34 — and, insofar as those individuals may be members or could become members, they would be entitled to the Charter’s protection against bills of attainder. The Resolution, however, does not impose punishment either in its function or its motivation.

Functionally, the Resolution merely establishes that the targeted individuals are “responsible for their statements, actions, or omissions”35 up through early 2016, serving a clear nonpunitive legislative purpose of “repeal[ing] the Amnesty Resolution”36 of 2016. Amending or repealing prior legislation is a clear legislative purpose that is regularly pursued without the appearance of punitiveness. Responsibility for one’s actions, furthermore, is hardly punishment, for common sense holds that individuals are, by default, responsible for their actions. After all, it is only logical that an individual is responsible for their own actions and statements unless otherwise provided for by law.

Motivationally, the legislative record evinces a clear intent to avoid the preemption of judicial trial, with the coauthors of the Resolution stating, for instance, that “[n]o judicial process is automatically initiated or concluded because of this resolution,”37 that determination of “whether any of those statements, actions, or omissions amount to a criminal offense remains the exclusive province of the High Court,”38 and that the Resolution “doesn’t charge anyone with any crimes.”39

IV

The Charter’s protection against bills of attainder, while younger than some other rights and freedoms guaranteed by the Charter, forms an integral component of the Charter’s guarantee of a right to a fair trial and criminal defense. Its provisions are rich in legislative and definitional context, and while it may not spring to life in this case, today, this hitherto untested provision of the Charter gains renewed definition.

It is so ordered.

Footnotes and References

  1. Assembly Resolution to Restore the Coalition of the South Pacific (2016, February 9). Retrieved 31 August 2024.
  2. Charter of the Coalition of the South Pacific; Article III, Section 2. Retrieved 31 August 2024.
  3. Levy, L. W. (1999). “Bills of Attainder.” Origins of the Bill of Rights, pp. 68–78. Yale University Press.
  4. Editors of Encyclopaedia Britannica (2004, June 18). “Attainder.” Encyclopedia Britannica.
  5. Cummings v. Missouri, 71 U.S. 277 (1867).
  6. Parliament of Canada (1995, November 28). “Bill Concerning Karla Homolka.” Senate Debates, 35th Parliament, 1st Session, vol. 3, p. 365.
  7. Polyukhovich v. Commonwealth (“War Crimes Act case”) [1991] HCA 32; (1991) 172 CLR 501 (14 August 1991).
  8. Fuertes v. Senate of the Philippines, 868 Phil. 117 (2020).
  9. Ibid.
  10. Polyukhovich v. Commonwealth, supra.
  11. Cummings v. Missouri, supra.
  12. United States v. Brown, 381 U.S. 437 (1965).
  13. Charter of the Coalition of the South Pacific; Article III, Section 2. Retrieved 31 August 2024.
  14. United States v. Lovett, 328 U.S. 303 (1946).
  15. Criminal Code; Article 3. Retrieved 1 September 2024.
  16. Nixon v. Administrator of General Services, 433 U.S. 425 (1977).
  17. Id., at 476.
  18. sandaoguo (2016). Working Group Drafts.
  19. Awe (2016). “RE: Great Council 2016: Voting.” Great Council 2016: Voting.
  20. The Charter of The Coalition of The South Pacific (2016).
  21. Charter of The South Pacific (2012).
  22. Charter of The South Pacific (2010).
  23. Charter of The South Pacific (2008).
  24. Charter of The South Pacific (2007). Archived 27 July 2024.
  25. Charter of The South Pacific (2006). Archived 27 July 2024.
  26. Southern Bellz (2013). TSP Residents Bill of Rights.
  27. Belschaft (2012). Bill of Attainder: Punk Daddy.
  28. Belschaft (2012). Bill of Attainder: Anur-Sanur.
  29. Belschaft (2012). Bill of Attainder: Antariel.
  30. Milograd (2012). Bill of Attainder: Belschaft.
  31. Belschaft (2012). “RE: Bills of Attainder.” Bills of Attainder.
  32. Merriam-Webster, Inc. Unlawful Definition & Meaning. Retrieved 1 September 2024.
  33. Merriam-Webster, Inc. Illegal Definition & Meaning. Retrieved 1 September 2024.
  34. Resolution to Restore Regional Accountability; Article 1, Section 4.
  35. Ibid.
  36. Welly (2024). “Post #6.” [2411.AB] Resolution to Restore Regional Accountability.
  37. ProfessorHenn (2024). “Post #4.” [2411.AB] Resolution to Restore Regional Accountability.
  38. Welly (2024). “Post #6.” [2411.AB] Resolution to Restore Regional Accountability.
  39. Kris Kringle (2024). “Post #47.” [2411.AB] Resolution to Restore Regional Accountability.

Submission: 18 Jul 2024 | Determination: 19 Jul 2024 | Ruling: 11 Sep 2024