Amicus Brief: Adhikari v. Kellogg Brown & Root

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

INTEREST OF AMICI CURIAE

Amici curiae are retired generals and admirals of the U.S. Armed Forces who spent their careers in the highest positions of command and staff in the United States and deployed overseas. Amici have a unique understanding of the United States’ deep and enduring commitment to opposing human trafficking worldwide. Amici understand the significant concerns for military safety and security if private contractors—acting under the authority of the United States and its military—are permitted to violate clear prohibitions on human trafficking with impunity. These concerns are heightened if, as here, the trafficking is directed toward an American military base within a region under de facto U.S. control.

The Supreme Court and this Court have recognized the value of the military’s experience and perspective on the application of U.S. laws on territories outside of the fifty states, including places and installations subject to U.S. military control. The identity and background of the amici are listed in Appendix A, attached. All parties have consented to the filing of this brief. No party’s counsel has authored this brief in whole or in part, and no person other than amici, its members, or its counsel contributed money intended to fund preparing or submitting the brief.