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President Obama To Congress: War Powers Act Doesn’t Apply To Libya

Taking a position that is certain to raise eyebrows, the White House sent a response to Congress today regarding the request for further information about the military action in Libya that argues that the War Powers Act is inapplicable to current American involvement there:

WASHINGTON — The White House is telling Congress that President Obama has the legal authority to continue American participation in the NATO-led air war in Libya, even though lawmakers have not authorized it.

In a broader package of materials the Obama administration is sending to Congress on Wednesday defending its Libya policy, the White House, for the first time, offers lawmakers and the public an argument for why Mr. Obama has not been violating the War Powers Resolution since May 20.

On that day, the Vietnam-era law’s 60-day deadline for terminating unauthorized hostilities appeared to pass. But the White House argued that the activities of United States military forces in Libya do not amount to full-blown “hostilities” at the level necessary to involve the section of the War Powers Resolution that imposes the deadline.

“We are acting lawfully,” said Harold Koh, the State Department legal adviser, who expanded on the administration’s reasoning in a joint interview with White House Counsel Robert Bauer.

The two senior administration lawyers contended that American forces have not been in “hostilities” at least since April 7, when NATO took over leadership in maintaining a no-flight zone in Libya, and the United States took up what is mainly a supporting role — providing surveillance and refueling for allied warplanes — although unmanned drones operated by the United States periodically fire missiles as well.

They argued that United States forces are at little risk in the operation because there are no American troops on the ground and Libyan forces are unable to exchange meaningful fire with American forces. They said that there was little risk of the military mission escalating, because it is constrained by the United Nations Security Counsel resolution that authorized use of air power to defend civilians.

“We are not saying the president can take the country into war on his own,” Mr. Koh said. “We are not saying the War Powers Resolution is unconstitutional or should be scrapped, or that we can refuse to consult Congress. We are saying the limited nature of this particular mission is not the kind of ‘hostilities’ envisioned by the War Powers Resolution.”

The administration unveiled its argument at a time when members of Congress have shown increasing skepticism about the Libya operation. On June 3, the House of Representatives passed a resolution declaring that the mission had not been authorized.

It’s worth taking a look at what the War Powers Act actually requires, so let’s take a look at 50 USC 1543:

In the absence of a declaration of war, in any case in which United States Armed Forces are introduced—

(1) into hostilities or into situations where imminent involvement in hostilities is clearly indicated by the circumstances;
(2) into the territory, airspace or waters of a foreign nation, while equipped for combat, except for deployments which relate solely to supply, replacement, repair, or training of such forces; or
(3) in numbers which substantially enlarge United States Armed Forces equipped for combat already located in a foreign nation;
the President shall submit within 48 hours to the Speaker of the House of Representatives and to the President pro tempore of the Senate a report, in writing, setting forth—

(A) the circumstances necessitating the introduction of United States Armed Forces;
(B) the constitutional and legislative authority under which such introduction took place; and
(C) the estimated scope and duration of the hostilities or involvement.

50 USC 1544(b) then requires:

Within sixty calendar days after a report is submitted or is required to be submitted pursuant to section 1543 (a)(1) of this title, whichever is earlier, the President shall terminate any use of United States Armed Forces with respect to which such report was submitted (or required to be submitted), unless the Congress

(1) has declared war or has enacted a specific authorization for such use of United States Armed Forces,

(2) has extended by law such sixty-day period, or

(3) is physically unable to meet as a result of an armed attack upon the United States. Such sixty-day period shall be extended for not more than an additional thirty days if the President determines and certifies to the Congress in writing that unavoidable military necessity respecting the safety of United States Armed Forces requires the continued use of such armed forces in the course of bringing about a prompt removal of such forces.

The question then is whether United States United States military forces are still involved in “hostilities or into situations where imminent involvement in hostilities is clearly indicated by the circumstances.” There seems to be no real contention by anyone that American forces, or NATO forces for that matter, are actually on Libyan territory or in Libyan territorial waters. The Administration seems to be arguing that since there are no American ground troops and no American fighter planes involved in action over Libya, then the answer to that question is no. As John Cole notes, though, we are using Predator drones to launch missiles at Libyan target on an as-needed basis, so the idea that we’re completely off the grid on this mission isn’t entirely true.

However, is an unmanned drone controlled from hundreds, or thousands, miles away really “engaging in hostilities” within the meaning of the War Powers Act? What about launching cruise missiles from a ship in international waters, would that be outside the purview of the WPA as well? Heck, would launching an Intercontinental Ballistic Missile from a silo in North Dakota toward Tripoli be covered by the Act? The answer is unclear:

It remains to be seen whether majorities in Congress will accept the administration’s argument, defusing the confrontation, or whether the White House’s response will instead fuel greater criticism. Either way, because the War Powers Resolution does not include a definition of “hostilities” and the Supreme Court has never ruled on the issue, the legal debate is likely to be resolved politically, said Rick Pildes, a New York University law professor.

“There is no clear legal answer,” he said. “The president is taking a position, so the question is whether Congress accepts that position, or doesn’t accept that position and wants to insist that the operation can’t continue without affirmative authorization from Congress.”

There’s also very little chance that the Courts will rule on this matter, for the reasons I discussed earlier today.

Of course, for the Obama Administration it’s not just a question of how Congress reacts, but also how the public reacts.  A response like this could potentially be spun as  the Administration trying to get around the requirements of the law by means of a technicality. The fact that we are still engaging in offensive action in Libya, albeit in a limited fashion that doesn’t endanger American forces, makes this kind of legal argument hard to sell — it’s a war they’re saying, but not a war war. That doesn’t strike me as something that’s going to play very well with the public, especially given how unpopular the Libya mission is to begin with.

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About Doug Mataconis
Doug holds a B.A. in Political Science from Rutgers University and J.D. from George Mason University School of Law. He joined the staff of OTB in May, 2010 and also writes at Below The Beltway. Follow Doug on Twitter | Facebook

Comments

  1. PD Shaw says:

    Did Obama submit a report to Congress pursuant to the statutes listed? I thought he had, but I’m not sure. If he had, then he’s conceded the War Powers Act applies, but is reduced to arguing that U.S. involvement has materially been reduced during the 60-90 days.

    I think Pildes is right, the courts won’t, and I would say shouldn’t, get involved in determining when the level of hositlities does or does not constitute war.

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  2. PD,

    Yes, he did.

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  3. george says:

    I think its a really bad idea to let presidents decide whether or not to send troops to a conflict in any capacity.

    The problem is that under a Democratic president the Democrats think its fine and the Republicans are against it, under a Republican president the Republicans will think its fine and the Democrats will be against it. But this isn’t a team sport where you always cheer for your team whether they’re right or wrong (no way that was offside).

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  4. Tano says:

    Seems pretty clear that the wording refers to the introduction of human assets into a situation in which they are in danger. (“United States Armed Forces are introduced…while equipped for combat, except for deployments which relate…”) i.e. not applicable to the Libya situation.

    especially given how unpopular the Libya mission is to begin with.

    When the Locerbbie bomber finally goes down, the popularity of the mission will be secured.

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  5. Wayne says:

    So the U.S. can launch missiles including nuclear ones and that is not a war as long as we don’t put boots on the ground?

    If it is not a full-blown war then it is not a war?

    We are spending millions of dollars, many military man hours and equipment in supporting these hostilities but we are not involved in these hostilities?

    Give me a break.

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  6. PD Shaw says:

    Thanks Doug (again).

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  7. Wayne says:

    George
    IMO Obama could get a resolution of some sort with republican support if he tried. Why he doesn’t try is beyond me. I was for Bush getting a resolution and he did. I don’t believe a President has to or should get a resolution for every decision. A President should be able to escalated, deescalate, and escalate once again without having to go back to congress every time.

    A President should get a general resolution like Leader A or Country A needs to comply with these demand or the President is authorized to use force to make it happen. After that the President should be given a good amount of leeway. That goes for Presidents from both parties.

    A President not getting any sort of resolution for long term action is not tolerable. That goes for Presidents from both parties.

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  8. David M says:

    The response is what I would expect from the executive branch, so I’m not really surprised by it. I do wish Congress would grow a spine and pass a more specific law if they don’t like this response.

    I do think voters won’t really care if no troops are deployed, so I don’t think it’s much of a political gamble.

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  9. PJ says:

    IMO Obama could get a resolution of some sort with republican support if he tried.

    I bet the republicans would demand Medicaid cuts to get their support. Or tax cuts.

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  10. Anderson says:

    So the U.S. can launch missiles including nuclear ones and that is not a war as long as we don’t put boots on the ground?

    I don’t think anyone’s ever imagined that, before pressing The Button in response to a Russian or Chinese first strike, the president would first have to obtain a declaration of war.

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  11. Tano says:

    I don’t believe a President has to or should get a resolution for every decision. A President should be able to escalated, deescalate, and escalate once again without having to go back to congress every time.

    So, your position is that the President should get a resolution in order to do the limited stuff he is doing now, but then once he has the resolution, he is free to escalate as much as he wants?

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  12. I don’t think anyone’s ever imagined that, before pressing The Button in response to a Russian or Chinese first strike, the president would first have to obtain a declaration of war.

    Except your hypothetical is not at all analogous to the Libya mission. Libya didn’t attack us, and they aren’t a threat to our interests.

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  13. Tano says:

    To follow up on my response to Wayne above…

    To give a President a resolution to deal with a situation, when the actions envisioned are minor, but then to accept that the President is free to escalate as much as he wants – this is the Gulf of Tonkin scenario that led to the escalation known as the Vietnam War. It was to prevent this from happening again that the War Powers Act was passed in the first place.

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  14. Jib says:

    George,

    It was not that long ago that there were congressman from both parties who would jealously guard the powers of congress from the executive branch but that is long gone.

    In the old days, pre-cold war, the standing armed forces were so small that the only way to go to war involved raising funds and forces just to fight. That required a debate in congress and a vote. A strong standing army creates the opportunity to fight with existing resources and since the President is commander in chief, it is very difficult for congress to stop any president who really wants to go to war.

    What about the fact this is a NATO operation. No one has mentioned this fact so I think it must not matter but we are obligated to defend NATO countries if they are attacked. Do we have any special treaty obligations if NATO decides to go to war without an attack on one of the nations?

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  15. Tano says:

    Do we have any special treaty obligations if NATO decides to go to war without an attack on one of the nations?

    NATO does not decide to go to war unless the US is on board.

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  16. michael reynolds says:

    As I’ve been suggesting for a while now, we are seeing a paradigm shift in war. We can hit very hard (conventionally) without risking so much as a single life. The temptation is obvious, and the usual counter-pressure — loss of American lives — is evaporating. Very interesting. We could, for example, remove every soldier from Afghanistan, and still make life impossible for a new Taliban government.

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  17. Steve Verdon says:

    Another American President grabs yet more power….shocking.

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  18. Tano says:

    Did Obama submit a report to Congress pursuant to the statutes listed?

    Yes, he did.

    It should be noted though, that the letter to Congress used the phrasing “…efforts to keep the Congress fully informed, consistent with the War Powers Resolution,” which is a very deliberate phrase that many Presidents have used, meant to signify that they were NOT necessarily conceding that the WPR applied to the situation. The standard language in these situations would be “pursuant to the WPR”, not “consistent with…”.

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  19. jes phillips says:

    Looking at the text of the resolution it explicitly states that a report is required (indicating that the president requires authorization after 60 days) when forces are deployed,
    “into the territory, airspace or waters of a foreign nation, while equipped for combat, except for deployments which relate solely to supply, replacement, repair, or training of such forces…”
    Full Text of Resolution

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  20. Tsar Nicholas says:

    As someone who’s far to the right of Ming the Merciless when it comes to executive power I can say with all sincerity that Rambobama rapidly is becoming my favorite Democrat president.

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  21. Tano says:

    “…it explicitly states that a report is required… when forces are deployed,
    “into the territory, airspace or waters of a foreign nation,”

    There are no forces deployed in Libya.

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  22. jes phillips says:

    Surely we are deploying forces into their airspace.

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  23. PD Shaw says:

    Tano: “they were NOT necessarily conceding that the WPR applied to the situation”

    That’s a fair point. Though I think we’re in a muddy area where if things go bad, Obama is out on a limb, and if things good good, Congress will crawl out to join him.

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  24. Tano says:

    Surely we are deploying forces into their airspace.

    Do unmanned drones constitute “armed forces”?

    I think not. “Armed forces” refer to human beings toting weapons.

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  25. jes phillips says:

    From the no fly zone to active air combat sorties we are surely inside their airspace with manned fighters. I think what they are trying to argue is that since the UN has authorized the action that they don’t need approval unless they escalate which they claim they can’t do under the UN mandate.

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  26. Tano says:

    I think what they are trying to argue is that since the UN has authorized the action that they don’t need approval

    Where do you get that? What relevance would UN authorization have to a question regarding the powers of the President vs. those of the Congress?

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  27. jes phillips says:

    Seems the resolution was intended to prevent putting US troops into a war zone and also to prevent escalations.

    They argued that United States forces are at little risk in the operation because there are no American troops on the ground and Libyan forces are unable to exchange meaningful fire with American forces. They said that there was little risk of the military mission escalating, because it is constrained by the United Nations Security Counsel resolution that authorized use of air power to defend civilians.

    They appear to be trying to address both points here.

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  28. Tano says:

    Seems the resolution was intended to prevent putting US troops into a war zone and also to prevent escalations.

    You mean the War Powers Resolution? I don’t think your characterization is completely right. It did not seek to prevent putting troops into a war zone. It did seek to prevent escalations without Congressional approval. It did carve out a considerable window for deploying troops before approval is necessary, so I don’t think it fair to say that they tried to prevent deployment.

    They argued that United States forces are at little risk in the operation because there are no American troops on the ground and Libyan forces are unable to exchange meaningful fire with American forces.

    Yes. In other words, there are no troops in harm’s way.

    They said that there was little risk of the military mission escalating, because it is constrained by the United Nations Security Counsel resolution that authorized use of air power to defend civilians.

    Yes. But that does not support your claim that the administration is arguing that the reason that the WPR does not apply is because the UN authorized the mission.

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  29. jes phillips says:

    Sorry I was a bit unclear in my post. I agree on your interpretation i just think they are cherry picking the 1st clause “into hostilities…” while ignoring the 2nd “into the territory…”. I don’t think they are arguing that it doesn’t apply because of UN authorization I think they are using it as cover to avoid the question.
    Nor do i think executive is prevented from deploying troops by WPR but it does seek to require authorization after 60 days which have now expired, if the initial conditions are met which it seems to me is the case here.

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  30. TG Chicago says:

    @Anderson:

    I don’t think anyone’s ever imagined that, before pressing The Button in response to a Russian or Chinese first strike, the president would first have to obtain a declaration of war.

    What if the president decided to launch the first strike himself? Legally, can he do that on his own personal whim?

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  31. Wayne says:

    The question isn’t if we can pound a much smaller country or get away with conducting war against them with little to no casualties. The question isn’t should we be at war with Libya.
    The question is can the President of the U.S.A conduct war with a country for more than 60 days without getting approval of Congress or if the WPA is unconstitutional can he conduct war with a country without Congresses approval.

    Re “think not. “Armed forces” refer to human beings toting weapons.”

    That is crazy. Missiles and drones are not part of our arm forces? You act like we have no responsibility for what our hardware does unless it is “manned”. A drone kills a bunch of innocent on purpose. No problem it wasn’t “manned”. Launching missiles at a country isn’t an act of war. Also you pretty much agree that without any threat the President could send a nuclear missile into any country like China, Libya, Iran, etc. It is not manned and it is not war since we have no boots in enemy territory. I can’t understand how anyone could think that way.

    Also acting like conducting war operations against a country doesn’t put are forces at risk unless their weapons have a longer range than ours is beyond me. The battle field is constantly moving. We hit their country they may hit ours or move forces into range to kill our troops. Granted Libya is not a big military threat but there are no rules that they must stay in their country and accept being pounded.

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  32. Tano says:

    Missiles and drones are not part of our arm forces?

    They are the arms, not the forces.

    You act like we have no responsibility for what our hardware does unless it is “manned”

    I don’t know what you are talking about. Who said anything about “we” having no responsibility. The issue at hand relates to the distribution of power between the executive and the legislature.

    you pretty much agree that without any threat the President could send a nuclear missile into any country .

    No, I imagine there are all manner of laws that prevent the President from starting a war for no reason. Of course, any President will articulate a reason, will define a threat. And then yes, they have the authority to order a missile strike without prior Congressional approval. How could they not have such authority given the time constraints involved in a war scenario like that? I imagine if they really fabricated a phony threat, or acted in a a manner that had no political support, then the Congress could avail themselves of the impeachment remedy. That would be, of course, after the fact.
    In any case, this has nothing to do with the issues we are arguing here in this thread. Whether Obama needs to stop the Libya action now, or last month, there is no question that he had the authority to begin it in the first place.

    It is not manned and it is not war since we have no boots in enemy territory. I can’t understand how anyone could think that way.

    I am not making grand definitional statements. I am trying to understand the wording of a particular law. I am not stating that it is not war if we do not have boots on the ground – but I am saying that my reading of the WPR seems to indicate that that particular law may not apply if there are not boots on the ground.

    Also acting like conducting war operations against a country doesn’t put are forces at risk unless their weapons have a longer range than ours is beyond me.

    Once again, the issue is the wording of the law. A theoretical risk does not seem to trigger the application of the law. If our forces were to actually become targets, were to actually be attacked, even if the battlefield were remote, then the law might well come into play.

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  33. ponce says:

    We can hit very hard (conventionally) without risking so much as a single life.

    America has had that ability for over 60 years.

    It was common decency, not loss of American lives, that prevented us from using it…

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  34. Rock says:

    What if the president decided to launch the first strike himself? Legally, can he do that on his own personal whim?

    No.

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  35. JKB says:

    Look, this is good news. We already have an umanned air force, once we get automated or remotely controlled robots, there will be no more war. As long as we don’t put any members of the Armed Forces on the ground, the president can kill, maim, destroy and generally rampage across the countryside at will.

    But there will be no war. Not to protest. Not to earn honors by serving in. Not to need Congressional declaration.

    So do we give Obama credit for ending war in our time?

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  36. Rob in CT says:

    *sigh*

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  37. TG Chicago says:

    @Rock: I tend to agree with you (at least, I believe that it shouldn’t be legal. I don’t know the applicable law well enough to say whether it is or not.

    But based on this interpretation of the War Powers Act, it would be legal for Obama to nuke Iran without consulting anyone, would it not?

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  38. Wayne says:

    Re “Once again, the issue is the wording of the law”

    The issue is the intent of the law and what it was written to do.

    The WPA was passed in order to reassert Congresses Constitutional authority as the one to declare war. It gives the President enough room to act in case of an emergency or eminent threat. However it put in measure to check the president power in committing the U.S. to arm conflict without the consent of Congress.

    Bombing or shelling the shit out of someone is an arm conflict and is considered an act of war. Trying to jump through hoops and twisting, reinterpreting and warping the wording of the law doesn’t change that. It also doesn’t change the intent of the law.

    If you want to claim that constitutionally the President doesn’t need Congresses consent to go to war, state so. I disagree but that argument makes sense. The Constitution states he needs it in all war not just close combat or this particular type. Claiming the President can conduct long range war because it is different doesn’t fly.

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  39. john personna says:

    This saddens me a bit, but doesn’t surprise me too much. Staff will encourage Presidents to take what power they can get, and most Presidents will succumb to that temptation.

    (I certainly don’t mind anyone beating the administration up about it. Their move is hardly praiseworthy.)

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  40. I’ve quoted you and linked to you here.

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  41. David says:

    If we’re willing to call international terrorism “warfare”, then there’s no way unmanned or remote attacks can get a pass. We are looking to assert influence in another nation by means of military strength, by reducing or eliminating strategic targets within that nation’s borders. Regardless of legality, moral opposition or whether you support Obama’s actions or not, it’s warfare, and I’m guessing the best people to answer that question are those that ARE on the ground in Libya – Libyans, innocent or not – who are the targets of whatever munitions we choose to deploy.

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  42. Tano says:

    Trying to jump through hoops and twisting, reinterpreting and warping the wording of the law doesn’t change that.

    You are the one who is going beyond a straight, literal reading of the text.

    It also doesn’t change the intent of the law

    Your interpretation of what the intent of the law was. Your interpretation is not objective truth. It is probably seeded with a grain of truth, but you stop looking for the actual, complex truth of what was intended, once you have enough to support your preconceptions. The WPR, like most pieces of legislation, was a compromise hammered out by a diverse set of legislators who had many different concerns. Reigning in the President was surely one concern. Insuring that the President had room to operate as CiC, and as architect of our foreign policy, was another. There may well be other perspectives that went into the mix. All of them combined, in the proper ratios, would make up some “objective” take on the intent behind the law. You have done nothing to try to understand that complexity – you only focus on the issues that support your position..

    If you want to claim that constitutionally the President doesn’t need Congresses consent to go to war, state so. I disagree but that argument makes sense

    No, it does not make sense. The Constitution is quite clear – only Congress can declare war.
    But there are lots of military actions that have not risen to the level of “war”. I put the word war in quotes because, sorry to say, there are different definitions of what war is. Any military action could be considered an act of war – the usage that you seem to be using. But the US has not been in a Constitutionally declared war since WWII – so you cannot deny that there is a unanimous consensus amongst elected and appointed officials – both parties, and all levels of the judiciary – that many types of military action do not fit under the definition of war.

    Not only Vietnam, but both of our current wars (all three if you count Libya) are undeclared. They do not seem to require a formal Congressional declaration of war. Vietnam, the Gulf War, and the Afghan and Iraqi wars all were of a sufficient level to require some Congressional authorization. Many interventions have not required Congressional approval.

    When is there a need for formal declaration? When do the specific provisions of the WPR come into effect. You can huff and puff all you want about how outrageous it all is, but at the end of the day, you have to read the text of the law, understand all of what the motivations were going in to it, and then construct an argument. That is what the administration has done in this case – I think you would need to do an equal amount of serious work to mount a credible critique.

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  43. Tano says:

    Regardless of legality, moral opposition or whether you support Obama’s actions or not, it’s warfare,

    Well that is a different discussion. What we are arguing here is the legality of the matter. What exactly does the WPR say. Calling it “warfare’ is merely a semantic stand. Whether it fits the defined conditions laid out in the WPR is the actual issue at hand.

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  44. bowman says:

    Tano, what do you believe are the intents of the WPA? Do you believe Obama has stepped over any of those intents?

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