UNITED STATES COURT OF APPEALS
                          FOR THE FIRST CIRCUIT

                __________________________________________

                                No. 97-1084

                __________________________________________

                         United States of America
                           Respondent, Appellant

                                     v.

                       Lui Kin-hong, a/k/a Jerry Lui
                            Petitioner, Appellee

                __________________________________________

                       ON APPEAL FROM AN ORDER OF THE
                        UNITED STATES DISTRICT COURT
                __________________________________________

                      REBUTTAL BRIEF FOR LUI KIN-HONG,
                            PETITIONER, APPELLEE
                __________________________________________

                                   Harvey A. Silverglate
                                   BBO#462640
                                   Andrew Good
                                   BBO#201240

                                   SILVERGLATE & GOOD
                                   83 Atlantic Avenue
                                   Boston, MA 02110
                                   Tel (617) 523-5933
                                   Fax (617) 523-7554


                                   February 21, 1997



                          TABLE OF CONTENTS

I.    THE GOVERNMENT'S NEW CLAIM BASED ON ARTICLE V OF
      THE 1972 U.K. TREATY FAILS.                                1

II.   THE GOVERNMENT'S NEW CLAIM, BASED ON THE TEXT OF, 
      AND CASE LAW CONCERNING, THE TAIWAN RELATIONS ACT,
      FAILS.                                                     4

III.  THE GOVERNMENT'S NEW, HYPOTHETICAL, UNPRECEDENTED, 
      AND UNCONSTITUTIONAL ARGUMENT THAT THE P.R.C. MAY BE SUBSTITUTED FOR 
      THE U.K. AS A SIGNATORY TO THE TREATY WITHOUT SENATE ADVICE AND 
      CONSENT SHOULD BE REJECTED.                                6

IV.   IN THE UNLIKELY EVENT THAT THIS COURT REVERSES THE 
      JUDGMENT BELOW, THE GOVERNMENT'S NEW ASSERTION THAT 
      THERE SHOULD BE NO REMAND FOR DISTRICT COURT 
      ADJUDICATION OF LUI'S FIFTH AMENDMENT AND 
      INTERNATIONAL LAW CLAIMS SHOULD BE REJECTED.              10

V.    CONCLUSION.                                               13



                        TABLE OF AUTHORITIES

                                   CASES

Ahmad v. Wigen, 
     910 F.2d 1063 (2d Cir.)
     stay denied, 497 U.S. 1054 (1990)                          11

In re Normano, 
     7 F.Supp. 329 (D.Mass. 1934)                               12

New York Chinese TV Programs, Inc. v.
U.E. Enterprises, Inc., 
     954 F.2d 847 (2d Cir.)
     cert. denied, 506 U.S. 827 (1992)                          4

Rosado v. Civiletti,
     621 F.2d 1179 (9th Cir.)
     cert. denied, 449 U.S. 856 (1980)                          11

Terlinden v. Ames, 
     184 U.S. 270 (1902)                                        7


                                  STATUTES

22 U.S.C. §3301 et. seq.                                        4, 5

22 U.S.C. §3303(c)                                              5

Hong Kong Policy Act, 22 U.S.C. §5701 et. seq.                  passim

28 U.S.C. §2253                                                 12

                           TREATIES AND CONVENTIONS

Extradition Treaty Between the Government of the
United States of America and the Government of the 
United Kingdom of Great Britain and Northern 
Ireland, June 8, 1972, 28 U.S.T. 227                            passim

Supplementary Treaty Between the United States of 
America and the United Kingdom of Great Britain and 
Northern Ireland, June 25, 1985, T.I.A.S. No. 12050             passim

                              OTHER AUTHORITIES

U.S. Department of State, United States-Hong Kong 
Policy Act Report, March 31, 1995                               5, 7

4 G. Hackworth, Digest of International Law, §§339, 
342 (1942)                                                      12

John J. Kester, "Myths of Extradition Law", 76 
Georgetown L.J. 1441 (1988)                                     12


I.   THE GOVERNMENT'S NEW CLAIM BASED ON ARTICLE V OF THE 1972 U.K. 
     TREATY FAILS.

     For the first time, the government claims that Article V of the 1972 

Treaty diminishes the probative force of the history and process by which 

the Supplementary Treaty was ratified -- probative in terms of the 

Supplementary Treaty's being taken as evidence of the drafters' intention 

that the Treaty be defined as applying only to the U.K. as the sovereign 

that may detain, try or punish Lui if surrendered.  However, the 

government concedes that even if Article V of the 1972 Treaty would 

theoretically be available for persons, such as Lui, who are sought by the 

United Kingdom Crown Colony of Hong Kong (UKCCHK) for economic offenses 

such as bribery, the law of the United States, as the requested Party, 

would exclude such offenses from the political offense exception.  

Government's Reply Brief (GR) at 8 n.9.

     Thus, according to the government, in the only cases where the 

political offense exception might realistically apply, the exception has 

been narrowed and, in such cases, "a new type of judicial inquiry 

altogether" (GR at 8) is authorized.  This "new type of judicial inquiry" 

under Article 3(a) includes determining whether, if surrendered, the 

relator "would be prejudiced at his trial or punished, detained or 

restricted in his personal liberty by reason of his race, religion, 

nationality or political opinions." 

     Contrary to the government's argument, Lui's ineligibility for 

Article 3(a) protection is no bar to the district court's examination of 

that provision, as one part of the integrated Treaty, in order to 

determine the Treaty's overall meaning, intent, and applicability.  

Indeed, judicial interpretation of the Treaty requires that all provisions 

be taken into account, regardless of whether Lui may rely upon any 

particular provision.  Lui need not be personally eligible for Article 

3(a) protection against abusive prosecution and punishment, in order to 

cite the article as proof that the Treaty's unusually narrow measure of 

protection is United Kingdom-specific.  To the contrary, it is precisely

because this Treaty is with the United Kingdom that the Senate has made 

Lui ineligible to defend against his extradition on the ground that, he 

would, if surrendered, face abusive and discriminatory detention, trial 

and potential punishment.  It is perfectly clear from the history of the 

adoption of the Supplementary Treaty that the Senate, had it meant for the 

treaty to apply to extraditions for trial and punishment under PRC 

sovereignty, would not have approved such a narrow political offense 

defense.  If there ever were an extradition treaty which would authorize 

the Secretary of State to surrender relators to face P.R.C. trial and 

punishment, the Senate might well insist upon protection against abusive 

prosecutions and punishment on terms similar to Article 3(a), but for the 

full range of extraditable offenses.  Lui, after all, is precisely the 

kind of person that the Senate would be wary to send to a P.R.C. sovereign 

for trial and punishment under a relaxed standard of protection for 

political dissenters.  He was born in China, but his family fled from 

Communist tyranny to Hong Kong in 1956.  His earliest education was in 

Christian schools in Hong Kong, but his family and school arranged for him 

to complete his secondary and higher education in Christian and secular 

institutions in Canada.  He and his family obtained Canadian citizenship 

so as to be safe from living under P.R.C.-rule in Hong Kong, and his 

resistance to being extradited into the hands of the PRC has been 

commented upon negatively by the Beijing government.  Lui would be capable 

of making quite a powerful record as a person eligible for the political 

offense exception, were he sought under a treaty other than this UK-

specific treaty.

     As reported by the Amici, P.R.C. transitional authorities have 

announced that all of the binding guarantees of fair trials, including 

prohibitions against discrimination, which are included in Hong Kong's 

Bill of Rights Ordinance, are to be repealed under P.R.C. rule, as will 

the British Law Ordinance which affords habeas corpus protection against 

unlawful imprisonment in Hong Kong.  Because Article 3(a) contemplates 

that, if surrendered, Lui's detention, trial and punishment would occur in 

UK courts and prisons and not those of the P.R.C., it does not apply to 

his bribery case and affords no protection from the P.R.C.'s abuse of his 

human rights, because he is a Christian, Canadian and capitalist refugee 

from Communist China, and now from Hong Kong.  For this reason, 

nothing in Article V of the 1972 Treaty does anything to affect the 

district court's correct conclusion that the Treaty, including Article 

3(a), does not grant jurisdiction to the Magistrate Judge to certify to 

the Secretary of State that she may surrender Lui for detention, trial or 

punishment under P.R.C. sovereignty in Hong Kong.


II. THE GOVERNMENT'S NEW CLAIM, BASED ON THE TEXT OF, AND CASE 
    LAW CONCERNING, THE TAIWAN RELATIONS ACT, FAILS.

    Though it did not say so in its opening brief, the government 

asserts in reply that the 1992 U.S.-Hong Kong Policy Act ("HKPA") 

"resembles the Taiwan Relations Act, 22 U.S.C. § 3301 et seq." which 

became law in 1979 (GR at 18).  This alleged "resemblance" supposedly 

means that, according to the HKPA, the UK Treaty authorizes extradition 

for detention, trial and punishment under P.R.C. sovereignty in Hong Kong.

     If there is any "resemblance", it is exceedingly remote.  Congress 

assuredly did not decide in 1992 that the P.R.C.'s resumption of 

sovereignty over Hong Kong would not require changes in previously 

applicable American treaty relations, as was the case when the U.S. 

withdrew diplomatic recognition of the Taiwan government.  No change of 

sovereignty over Taiwan occurred.  The differences between the two 

statutes, and the contrasting circumstances which prompted enactment, are 

added proof that the government's HKPA argument should be rejected.

     In the case of the Taiwan Relations Act ("TRA"), the political 

branches clearly strove to maintain unchanged treaty relations with Taiwan 

(including defense assistance primarily against the military threat posed 

by the P.R.C.), notwithstanding America's withdrawal of diplomatic 

recognition of the Republic of China as the sole Chinese government.  See

New York Chinese TV Programs, Inc. v. U.E. Enterprises, Inc., 954 F.2d 

847, 849-51 (2d Cir. 1992).   In the case of Hong Kong, part of the 

territory of America's closest ally (with an existing set of bilateral 

treaty relations) is to become part of the territory of a totalitarian 

regime with which America maintains often-strained relations, including 

entirely different treaty relations.  Because of this enormous difference, 

the TRA provision concerning the continuation of treaties, 22 U.S.C. § 

3303(c), states unqualifiedly that all such agreements shall remain in 

force after the Taiwan government's loss of diplomatic recognition.  This 

Taiwan provision is similar to the first sentence of the Hong Kong Policy 

Act's treaty provision, 22 U.S.C. § 5721(b).  It is crucial to note, 

however, that the TRA lacks a provision "resembling" the last sentence of 

§ 5721(b); nor does it have other text or legislative history comparable 

to that under the HKPA.  This legislative history demonstrates that the 

State Department and the Congress have consistently stated that the U.K.. e

extradition treaty would not be appropriate to continue in force after the 

reversion, and would therefore have to be replaced by a new treaty 

requiring Senate ratification.  Unlike in the Taiwan situation, where the 

Second Circuit properly recognized that the political branches had decided 

that treaties which pre-dated the de-recognition date should not lapse 

thereafter, the government cannot deny that the President has formally 

stated, in the 1995 Hong Kong Policy Act Report, that as of the reversion 

date the U.K. extradition Treaty will have to be replaced.  Add. 74.  

Indeed, the Executive's own conduct confirms this through its negotiation 

of a proposed treaty that is about to be submitted to the Senate.  The 

government conceded in the district court that, so long as the legal 

status of the Treaty remains unchanged, and no other treaty is ratified 

and in force, the Treaty will lapse on the reversion date.  A. 310.

III. THE GOVERNMENT'S NEW, HYPOTHETICAL, UNPRECEDENTED, AND 
     UNCONSTITUTIONAL ARGUMENT THAT THE P.R.C. MAY BE SUBSTITUTED FOR THE 
     U.K. AS A SIGNATORY TO THE TREATY WITHOUT SENATE ADVICE AND CONSENT 
     SHOULD BE REJECTED. 

     The government is unable to rebut the evidence in the text, history, 

and reports issued under the HKPA, to the effect that both political 

branches have always understood that it would take a new, Senate-ratified 

treaty to authorize extraditions to the courts and prisons in P.R.C.-

controlled Hong Kong, depending on a judgment made by both political b

branches concerning the extent of China's adherence to the Joint 

Declaration and any other relevant factors.  Perhaps, in the light of 

recent events in China and Hong Kong, the Executive now lacks confidence 

that the Senate will ratify the proposed treaty (A. 26-27), especially 

since the Executive is obliged to file a HKPA report to Congress on March 

31, 1997 (Add. 68) concerning the P.R.C.'s expressed intention to use 

Beijing-appointed, undemocratic institutions to make Hong Kong's Bill of 

Rights Ordinance non-binding, and to repeal habeas corpus, and because the 

Senate has already expressed its sense that the PRC is violating the Joint 

Declaration. (Add. 86) 

     For the first time on appeal, the Executive in its reply brief 

expresses its willingness to renege on assurances given to the Congress -- 

both prior to enactment of the HKPA and in the 1995 HKPA Report (Add. 74) 

-- that the Senate's prerogative would be respected concerning 

extraditions to post-reversion Hong Kong.  The government reports that it 

has discussed this evasion of the Senate with "Hong Kong and PRC 

officials."  GR at 17 n.16.

     In this astonishing footnote 16, the government cites the inapposite 

"state succession" cases mentioned by the Magistrate Judge, as if the 

Senate's Advice and Consent to extradition relations with the U.K. would 

be transferrable to the P.R.C.  Because the Chinese have not yet even 

agreed to this maneuver, this Court can properly ignore for now the 

government's hypothetical suggestion.  However, the government seeks to 

make the suggestion less hypothetical by arguing from the false premise 

that "if" the Senate's Advice and Consent is unnecessary to continue the 

U.K. Treaty in force into the post-reversion period, then Lui's claim that 

his extradition lacks current Senate approval must fail, such approval 

being unnecessary.  However, the government runs head-on into the fact 

that the State Department is on record stating to the Congress that the 

change in sovereignty over Hong Kong is not a state succession (Add. 49); 

neither has it shown that Terlinden v. Ames, 184 U.S. 270 (1902), and its 

progeny apply here, those being inapposite state succession cases.  As the 

district court noted, the Senate's Resolution of Ratification expressly 

warned against using the Treaty's provisions for extradition relations 

with any other sovereign without further Advice and Consent, and the 

Treaty's political offense provisions were not to be used to form a 

relationship with any non-democratic or totalitarian regime.  A. 200.

     At bottom, Lui maintains that, under the Fifth Amendment's Due Process 

Clause and the Advice and Consent Clause, the Senate's Advice and 

Consent to the terms of an extradition relationship with the U.K. is not 

transferrable to the P.R.C. at the whim of the State Department.  China is 

not a newly-emerged sovereign which has been relieved of its colonial 

status and has agreed with the U.S. to succeed to the U.K.'s shoes as a 

U.S. treaty partner, as was the case for Canada or the Bahamas.  China is 

a sovereign arguably older than the U.K.  Hong Kong's territory is being 

ceded from U.K. sovereignty to become part of the territory and 

sovereignty of China.  China has long had independent treaty relations 

with the United States which are very different from U.S.-U.K. Treaties.  

Because of the liberty interests at stake in extradition treaties, and the 

imperative to preserve its careful allocation of powers, including checks 

and balances in the conduct of foreign affairs, our Constitution requires 

Senate approval to establish an extradition relationship with the P.R.C.  

Because of its status as an international human rights scofflaw, no 

country in the world formed an extradition relationship with the P.R.C. 

prior to 1996, when Russia and Byelorussia did so.  The Constitution's 

design and fundamental liberty interests require that when, if ever, 

America announces before the world that this nation has sufficient 

confidence in P.R.C.-controlled courts and prisons in Hong Kong to 

extradite people there on terms similar to (or, more likely, very 

different from) those in the existing U.K. Treaty, the voice of the Senate 

must be heard.

     If it is not by now perfectly obvious that a U.S.-U.K. treaty may 

not be the basis for extraditing Lui to stand trial in courts of the 

P.R.C. sovereign (the government's theory being that in some casuistic 

fashion Hong Kong will not really be part of China because the P.R.C. has 

promised the U.K. that Hong Kong will be allowed some degree of autonomy), 

it becomes so when one examines the enormous implications of the 

Executive's extraordinary and unprecedented claims in its Reply Brief.  

The government claims (GR at 17, n. 16) that it can proceed to extradite 

Lui to Hong Kong, for a post-reversion trial, under the current U.K. 

treaty, since that treaty could in any event survive into the post-

reversion period by the mechanism of "state succession," all without 

Senate Advice and Consent.  Yet in the record below (A. 26) is a 

Declaration of Jamison S. Borek, Deputy Legal Adviser in the Office of the 

Legal Adviser, Department of State, in which the government advises that 

Hong Kong and the P.R.C. will shortly conclude a treaty allowing 

extraditions from the Hong Kong Special Administrative Region ("HK-SAR") 

into anywhere in the rest of China.  Under the theory set forth by Ms. 

Borek, the only thing that would then prevent HK-SAR from re-surrendering 

someone like Jerry Lui to the hands of the mainland Chinese authorities 

would be the "specialty" provision of the Treaty, which prohibits the 

requesting country from re-surrendering the extraditee to a third 

sovereign.  Again according to Ms. Borek, the Secretary of State has the 

power to waive specialty protection.  What this means, of course, is that 

if the government's theory is allowed to stand, this Court would have

approved, indeed facilitated, the extraditions of free citizens from U.S.

soil to China, via the way station of Hong Kong, with nothing more than a

waiver by the Secretary of State, and with no role for the Senate.  Merely 

to state this proposition is to refute it.

     For these reasons, the government's hypothetical postulate that 

Senatorial Advice and Consent can be dispensed with by assigning to the 

P.R.C. the U.K.'s position as an extradition treaty signatory will not 

withstand constitutional scrutiny.

IV.  IN THE UNLIKELY EVENT THAT THIS COURT REVERSES THE JUDGMENT BELOW, 
     THE GOVERNMENT'S NEW ASSERTION THAT THERE SHOULD BE NO REMAND FOR 
     DISTRICT COURT ADJUDICATION OF LUI'S FIFTH AMENDMENT AND 
     INTERNATIONAL LAW CLAIMS SHOULD BE REJECTED.

     The government argues for the first time in reply that Lui's claims 

under the Fifth Amendment's Due Process Clause and Multilateral Human 

Rights Conventions are barred by the non-inquiry doctrine because this 

would supposedly involve a prohibited inquiry "into the requesting 

country's legal system,"  GR at 19-21, and that this precludes a remand if 

there is a reversal.  Lui's due process and human rights claims do not 

involve any inquiry concerning the legal or prison system of the UKCCHK, a 

U.S. treaty partner.  Hence, the rule of non-inquiry does not bar them. 

     The government also argues that Lui's Fifth Amendment and human 

rights claims are solely for the Secretary of State, quoting the assertion 

in Ahmad v. Wigen, 910 F.2d 1063, 1067 (2d Cir. 1990) that, so far as that 

Court knew, the Secretary had "never directed extradition in the face of 

proof that the extraditee would be subjected to procedures or punishment a

antipathetic to a federal court's sense of decency" and added that "it is 

difficult to conceive of a situation" in which this would occur. The 

liberty interests of everyone in America are ultimately entrusted to the 

federal judiciary through its habeas corpus jurisdiction.  Rosado v.

Civiletti, 621 F.2d 1179, 1197 (2d Cir. 1980).  The reality is that the E

Executive's record has been neither as pristine nor as trustworthy as the 

Wigen Court supposed.  History shows that the same district court which 

seeks to protect Lui here, protected a Jew, Joao Normano, from the State D

Department's decision to extradite him into the hands of Nazi justice in 

1933 and 1934:

     The attorneys for Isaak Lewin, otherwise known as Joao Frederico 
     Normano, in urging in 1933 against his extradition from the United 
     States to Germany, raised the point that, being a Jew, he would not 
     receive a fair trial from the authorities then functioning in 
     Germany.  Joseph R. Baker of the Legal Adviser's Office of the 
     Department of State, in commenting thereon, said:

     ...it may be stated that determination of this matter involves 
     a question of policy which is not within the legal domain.  
     However, it may be suggested in this relation that the 
     provisions of the Extradition Treaty between the United States 
     and Germany do not appear to afford any basis for refusing 
     extradition on this ground.  Possibly if it shall be decided 
     that Lewin should be surrendered it would be appropriate to 
     suggest in the note with which the warrant of surrender is 
     transmitted to the German Embassy that objection has been 
     raised to the surrender of Lewin on the ground that under 
     existing conditions in Germany he could not hope to receive a 
     fair trial and that the Department desires to have the German 
     Government informed of this objection while not assuming that 
     it is well grounded.

     Memorandum of April 4, 1933, MS. Department of State, file 211.62 
     Lewin, Isaak/22 _.  The sense of the foregoing was embodied in the 
     note to the Embassy. Ibid. /23.

4 Hackworth, Digest of International Law §§ 339, 342 (1942); see In re

Normano, 7 F.Supp. 329 (D.Mass. 1934)(granting writ of habeas corpus); 

and, see generally, John J. Kester, "Myths of Extradition Law", 76 Geo. L.

J.1441, 1484-89 (1988). 

     The district court conducted no proceedings concerning Lui's Fifth 

Amendment and human rights claims, except to note that Lui's claims are 

"not frivolous."  A. 202.  Lui has not yet had a full opportunity to make 

the required factual record which will require supplementation and, almost c

certainly, the taking of live testimony, including Lui's testimony that 

was erroneously precluded by the Magistrate.  

     Lui's probable cause claims concerning each one of the nine 

certified charges as well as his human rights claims are not before this 

Court and the record is not fully developed.  On this record, there is no j

jurisdiction under 28 U.S.C. § 2253 for this Court to consider their 

merits.  The government notes that Lui's claims refer to many issues, 

including the Magistrate Judge's refusal to consider polygraph evidence 

showing that Lui is innocent of bribery, and as corroboration of 

exculpatory affidavits submitted by defense witnesses which the Magistrate 

Judge's opinion shows he failed to consider at all.  All of these issues 

deserve and require the district court's thorough consideration.  In its 

remarkable footnote 16, the government states that it has the option to 

continue this extradition effort even after the reversion date, no matter

which way this Court rules, by relying upon a PRC-signed treaty which has 

not received the Senate's imprimatur.  Hence, the government's position 

undermines any claim that it would be prejudiced by further district court 

proceedings.

V.   CONCLUSION.

     For all the foregoing reasons, and for those set forth in Lui's 

opening brief, the district court should be affirmed.


                                         Respectfully submitted,

                                         Harvey A. Silverglate
                                         BBO#462640

                                         Andrew Good
                                         BBO#201240
                                         SILVERGLATE & GOOD
                                         83 Atlantic Avenue
                                         Boston, MA 02110
                                         (617) 523-5933

Dated: February 21, 1997