The Gary McKinnon litigation: a continuing legal battle

Gary McKinnon was accused of accessing US government computers without authorisation, but will new evidence of his Aspergers Syndrome be a defence for his actions? Would he have acted differently but for his condition?
The facts
The Gary McKinnon litigation concerns a 43-year-old British citizen who, between 2001 and 2002, is accused to have allegedly gained unauthorised access to 97 United States (US) government computers, deleted data and caused damage amounting to $700,000. The US government requested extradition of the defendant after McKinnon rejected a plea bargain in 2003, and this was considered in the House of Lords, in McKinnon v United States [2008]. The defendant argued that the plea bargain constituted ‘unlawful pressure’ and had amounted to an abuse of process. The appeal was unanimously dismissed because the circumstances of the case were not severe enough to resist extradition. However, in June 2009, an appeal went to the Divisional Court, in R. (on the application of McKinnon) v Secretary of State for Home Affairs [2009]) requesting judicial review of decisions made to extradite him after it was discovered that he was suffering from Aspergers Syndrome in August 2008. He had claimed that extradition would breach his rights under Article 3 (the right not to be subject to inhuman or degrading treatment or punishment) and Article 8 (the right to a private and family life) of the European Convention on Human Rights. Again, the appeal was dismissed, and judges affirmed the House of Lords decision in the previous case; the case did not ‘approach Article 3 severity’ (Burton LJ).
Fresh hope
Following years of stressful and expensive litigation, the New Year proves to be a happy one, as it sees High Court judge, Mr Justice Mitting, granting the judicial review of the possible unlawful decision of the Home Secretary to extradite McKinnon. The review will be heard later this year in the divisional courts and will consider the Home Secretary’s decision to ignore new evidence from a consultant psychiatrist, against extraditing McKinnon, that self-harm or even suicide is an ‘almost certain inevitability’. This recent update on the McKinnon case forces us to consider two important legal issues existing between the American and English legal systems: how worthy are plea bargains, and could the Home Secretary’s decision to extradite Gary McKinnon be considered unlawful?
Unfair bargain
A plea bargain is an agreement between the prosecution and the defendant in a criminal case, which means that, if he pleads guilty, he will get, inter alia, a lesser sentence, subject to court approval. Plea bargaining is controversial for many reasons, and perhaps rightly so. In the first McKinnon case, it was argued by defence lawyers that plea bargaining puts unfair pressure on the defendant to give up his legal rights to a trial by jury, so it could be considered unconstitutional and an abuse of process. Victims may consider plea bargaining unfair because, despite being guilty, the defendant may receive a lighter punishment where it is not deserved. The possible long-term consequence of this is that it may result in people having less faith in their justice systems. Plea bargains have been defended by criminal justice systems like the US Supreme Court, alleging that they save court time and therefore more efficient. Are the benefits of plea bargaining purely for the courts, rather than for the individuals concerned?
After considering the lawfulness of plea bargaining in the 2008 case, it is easy and perhaps understandable to feel sceptical and unsympathetic towards McKinnon. In my opinion, the defence were trying to delay the extradition proceedings as much as possible. I agreed with the judge’s decision to dismiss the appeal on the basis that plea bargaining, although not strictly used in the UK, is regulated in the US and therefore lawful. However, what made the case an interesting one to follow was how my views changed when reading as the case progressed, and how I learnt more of McKinnon’s troubling situation. Further, the psychiatrist’s findings in the second case, suggest that Aspergers Syndrome makes him less blameworthy for his crimes. This is possibly due to the ‘obsessions’ or ‘strong narrow interests’ symptomatic of Aspergers Syndrome, which led him to believe that the US government were concealing information that would be in the public interest, and therefore a moral and ethical issue that he felt obliged to reveal. In January, a human rights barrister agreed that his motivations in committing the crime were controlled by an underlying mental disability and claimed that the government, in extraditing McKinnon, would ignore the UK Bill of Rights of 1698, which proposed to ban punishment which does not fit the crime. Perhaps gaining access to these computers became a personal challenge to him, therefore the assumptions that his conduct was ‘intentional and calculated to influence the United States government by intimidation and coercion’ seem less convincing, and perhaps he was unaware that this would be the consequence of his actions. People supporting his extradition might say that having Aspergers Syndrome does not necessarily mean that he cannot distinguish right from wrong.
The alternative
Will McKinnon’s Aspergers Syndrome change his sentencing? Should people with mental disabilities be treated differently under our legal system? Is it fair to give two people who committed the same crime but have different mental states different penalties? Perhaps he could be given an alternative punishment which would not harm him mentally, as he clearly deserves punishment; but the punishment which the US is suggesting could lead to mental distress. If he were to be extradited and imprisoned in the US it could become a moral concern because he could suffer a mental breakdown. Arguably, he would be suffering for a crime where no harm was committed. There are some questions which still remain: should it matter where he is punished, provided that he is? Alternatively, is it fair for the US to punish him there when he committed his crimes in the United Kingdom? And finally, should the decision to extradite McKinnon be held unlawful? This will be decided later in the year.
Clare Taylor is in the first year of a Law LLB with French







March 24th, 2010 at 1:57 am
The facts: There is no evidence nor admission that Gary McKinnon deleted anything other than his own traces, nor that he caused a single dollar worth of damage. The report of eminent forensic IT expert Professor Peter Sommers presented to the court under Lord Justice Stanley Burnton attests to this, as does the CPS lawyer Russell Tyner. The judge and prosecution both agreed that to prosecute on the extradition offences alleged by US would be “an embarassment to the prosecution”.
In order to create an extraditable offence (as opposed to the Summary Offence of Computer Misuse Level1 for which evidence and admission do exist), the US conveniently alleged exactly $5000 of damage per machine, which just happens to be the minimum threshhold required for extradition. This alleged “damage” has been shown in court to represent nothing more than the cost of installing the basic firewalls and passwords that should have been on the systems in the first place.
It is telling also that instead of requesting extradition in a timely manner, the US waited THREE YEARS to make their request, coinciding with the introduction of the Extradition Act (2003), under which a prima facie case no longer has to be presented in order to extradite.
Regardless of the established legal concept of “diminished responsibility”, Gary McKinnon should not be extradited, since the extradition allegations against him are not supported by any evidence at all, and moreover, the assessment of the evidence by the courts is such that “a reasonable person, acting without prejudice” would have no grounds for suspicion that the alleged offences ever took place, much less that Gary committed them. As such, extradition is not supported by the current treaty, rotten though it is, and is in clear violation of HRA Arts.2,3,6,7 and 8.
March 24th, 2010 at 1:59 am
Oh, and ps – when exactly was Gary McKinnon found guilty of anything? He hasn’t yet been tried under anything other than the extradition proceedings. Surely he is innocent until proved guilty?
March 24th, 2010 at 2:08 am
Your assumption that Gary McKinnon has been found guilty is completely erroneous. Under the 2003 extradition treaty British Citizens are denied the right to any trial. Moreover the actual facts of the case are somewhat different to what authorities would have you believe.
During an extended police interview without the benefit of a lawyer or an appropriate adult being present the only thing this vulnerable man admitted to was illegal access, that is ‘just looking . Illegal access is not an extraditable offense – it carried only a six month sentence in the UK. According to Microsoft, technically he did not even hack as there were no passwords and no firewalls. He even left many notes telling them that their security was ‘crap’. The Hi Tech Crime Squad also said “we have been monitoring your computers for some months and as you have done nothing that could cause damage, you’re looking at six months community service”. Despite this, the US authorities were desperate to make an example of this man and wanted to extradite him. To be able to extradite there has to be a minimum of $5000 of damage, so the US claimed that Gary McKinnon had caused the magic $5000 worth of damage on each system he accessed including six university computers each of which later publicly denied any damage was done. Undeterred the US issued a superseding indictment omitting the contradictory universities. Had the US tried to extradite Gary at that time, they would have had to prove the alleged damage in a UK court of law which, of course, they could not do. Evidence given to the Crown Prosecution Service was dismissed by the CPS as hearsay and inadmissible and unable to be adduced. But instead, America waited over three years until the UK started using the one-sided unbalanced extradition treaty which meant they did not have to provide a scrap of evidence to justify their claims. Under the 2003 extradition treaty the US does not need to provide any evidence to extradite a UK citizen merely a suspicion. Whereas the UK does have to provide proper contestable evidence to extradite a US citizen because the US protects its own citizens unlike the UK government who gave away our right to a fair trial by a jury of our peers, and our right to be innocent until proven guilty , this they did in secret without parliamentary debate and without any apparent compulsion, deliberately avoiding the democratic process by using ‘the queens prerogative’ an arcane power of the monarch which Jack Straw denounced as ‘having no place in a modern democratic society’ and the Labour Party itself stated: “It is where power is exercised by government under cover of royal prerogative that our concerns are greatest… Here massive power is exercised by executive decree without accountability to Parliament and sometimes even without its knowledge” despite the labour party’s great concerns they went on to do just that very thing: sign away our rights without parliament’s knowledge. Gary McKinnon was not in America he was here in the UK. He was no more connected to America than if he called them long distance. Cyberspace has no more legal existence than does Never-never land. Gary McKinnon did not cause any damage. If he was such a danger to US systems as they would have us believe, would they have left him with unrestricted internet access for over three years? NO!
March 24th, 2010 at 3:18 pm
In Addition Plea bargains are totally counter to Justice they only serve expediency.
In the US 96% of cases do not go to trial.
In the case of Gary McKinnon, he was threatened that, unless he relinquished his legal UK rights, he would be sentenced to the max (ie 10years per count, 7 counts), denied repatriation and that one state “wanted to see him fry”.
For several reasons, including that the U.S refused to put an offer in writing or to give any guarantee re-the proposed plea bargain, Gary McKinnon refused to entertain the proposal.
The said threats came to light because, although intended to be kept secret, the prosecution inadvertently referred to the conversations during the hearing and the brilliant Edmund Lawson QC jumped on that and brought the whole plea bargain threats into the arena.
The question of the huge disparity of sentence and the coercion to give up uk rights, was brought before the Lords. (Edmund Lawson QC was unwell and sadly died soon after the Lords hearing) The QC who stood in for Edmund Lawson QC, performed poorly and failed to argue the points and the disparity of sentence was dismissed. The ’stand in’ QC (who a short time after was made a Lord) volunteered that the horrendous threats could be viewed as incentives ??
Lord Justice Stanley Burnton’s comment on the outrageous hypothetical ideas put forward by the Lords was “and pigs might fly”
Justice should not be bought and sold or bargained away. there is no place within natural justice for plea bargains which often persuades innocent people to plead guilty in order to get a lighter sentence and put an end to their nightmare.
March 24th, 2010 at 4:37 pm
Despite the above comments, I think that it is important to encourage first year students to take an interest in current awareness. Although you will learn from your mistakes, I credit you for taking your time to write the article and showing an interest. I found the article interesting to read.
March 24th, 2010 at 7:48 pm
Plea Bargains
“In Addition Plea bargains are totally counter to Justice they only serve expediency”
Expediency is not an aim that is counter to justice.
No defendant is forced to take up the offer of plea bargains
Refusal to take up plea bargains means the prosecution have to proove guilt beyond reasonable doubt – by no means an unfair standard.
March 24th, 2010 at 8:02 pm
Hear hear! Plea bargains amount to coercion and perverting the course of justice, surely…
June 10th, 2010 at 2:17 pm
Dear Clare,
Your analysis is entirely proper and correct. This topic has been exhaustively examined on the Jack of Kent blog to which I refer interested (and open-minded) readers.
http://jackofkent.blogspot.com/
IMHO, many of the comments above are ill-informed.