# Petition for Writ of Certiorari — Bjorson v. United States (No. 632) > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386420_0245%3A2 ## Record - **Collection:** Supreme Court brief - **Document type:** Petition for Writ of Certiorari - **Published:** January 1, 1959 ## Text . & ai : _ a ;, . | a } he JY. JAMES R. BROWNING, Cler | Supreme Court of the United States wer - Ocropien, Pram, Phot ’ No. 632 re A OS . ° DEAN EJNARD BJORSON, Petitioner, * - | | ¢ rs a. } . _» UNITED STATES or AMERICA L , Petition for Writ of Certiorari to the United States Court of Appeals. | | Uae UCR For the- Ninth- Cireuit_— > 3° canna “ \ Haypen ©. COVINGTON 124 Cobunbia Pleights Brooklyn 1, New York ? : Counsel for Petitions - bd , “a y . *- : ’ . * e a ; é r ae » mn a . i . ‘ s . 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Sn. ce ys’ nies, e Statutes and regulations involved oo. 00.0000... — Statement of the ease oo... 6... ee Neecicias i es S Reasons for ranting the Writ 1 eae ne Pe Conmelusion ....).....; Paap e's Aa eds ae "Pete yee Bd Appendix A (opinion of Court of Agopeals) RNs 14 ‘Appendix B (judgment of (Murtot Appeals Teerry sae Saar ; SS, SSS : . : Vi Casks Crrep . | > Dedezv U nite States | oe 1. BES, 342- Ta. 4s pote (i Mi) ee a Ma . histe 3 eg ‘aited States . . ate TUES. LIAL T5116 (18465) Race. meer cet fie alla ogy States*—- ar ot ee |e HH, 2D (UME) oo RET Soke oe See Korte ve U a States Sth . j No. 497, October Term, 158 peert, ide ne 3 jos b, 828 (opinion. below, J6Q F.2d 6335) (oth © ir asi p- 2 l nites Su ate ~V. —o 3 ——_- — are Cal. Ran’ feels 1. Lad CE po Srapered ake Ria es —“Thpartment of the Army Special Regulations, ap: proved: 10 April. 1953 tee ES I ee ete ae . SHGISASO-T, par Wd 00... elit een Neg Goin Ge ai SRGISTSO-T, pars WT) 2020.8, Bratt eure eae ee Se Ore een eae ere a SN. SRGI-180-1, par. 142.02... ieee ge "Tee eo ae? | | ‘ i : f a] ie eo @ « a- Sarees, Np Recerarions Crrep continued Meade ral Rules of ¢ Crinninak P rocedure, Rules (hoe), GUESS. Sas ulieii dees UA RES Kerek che BA eS Selective Servier “Regulations (32 « Up I. Sevtion AGO ef seq) ye, . * Mection ek Aerie PRR iF oer MT ee ee oe Section 628.10 United States Code Tithe ES, Section SN, a ins biccan ee Aa EEA Title 2S, See tion POUR Dn sa 2s eae AF tS ROD ek ee Se ee oe ee ee ee ee ee en Se ee ‘Title 50, Appendix, Sections 451-470 (0 niversal Mikitary Training and Service Act) SNoctign: 41(¢) Peete eee eT eT eer ee oree ns wee Section 456()) 2... - i abe wahak ses aU Ae OPES oy ee a | Ce ree Mieke Section 462 (a) hoe Wee eats s ye eee iasaus | 8 | \ a . : - rm . — ‘ >. é - Ae P oe " o we P ; | ii Supreme Court of the Anited States 4 ier — Oeronen Tra, 19 j ; DEAN*EJNARD BJORSON, Petitioner i a ; ‘ i ; a i c—- UNITED ST ATES OF DF ANH ee | \ nae. S, , es c 4 ; Ps oe / 3 . _ an a, Sotee “d Statey’ Cinix of hingwale . For the Ninth Circuit To THe Scepiue Cover or tik UNeren Nrares: ‘Potifiornfer, prays that ao writlof éertiorari issue te, i co a Atel judaine ntsof the United States Court of Appeals: for thé Ninth Circuit affirming the judge ntoof the United: States: Distriet Court’ for the Nertliern Distriet of Cait fornia, Nouthern Division. convieting the ‘petitioner oof a Violation of th® Universal Militiry Training and Service Net > and sentencifi him to the custedy of the Attorney General, _ ordered to dp civilian work, had failed to exhaust bis - administrative - reinedies because he did not go “to the i, is OPINION BELOW The opinion of the € ‘our of Apped@s is not vet re ported, a lt ix printed as Appendix’. A to this metition, of rd.,, pacer’ "14-25: , | JURISDICTION Deal eet es The judgment of the ¢ Court of "Aegeale Was entered on, November 18, 1959, (See Appendix: B- to this petition for- 7 of certiorari, infra, page 26.) “Phe time for filing thif petition for writ of certiorari. wag extended by an | s order of: Mr. Justice Doug! as dated December Oe” 1a, to and-including January 9 1960. This petition for writ of certiorari is, therefore, filed within time. The jurisdiction of this Court is invoked under 28 UL SLC. S 125401). (See ‘also Rules 37(b)(2) and 45(a), Federal Rules ef Critninal, Protedure.) Thee district cottrt had jurisdiction under IST RC. SS: -; od . . ‘QUESTIONS PRESENTED -. “ . * © e 6 . Ne’ OL ' oe an Oe Whether the Re Court of Appeals interpreted the Act and -— ations (that petitioner, a conscientious objector brink” by reporting to the Lox Angeles County Department of Chiatities as erdered to do so by his local board). con: ~ trary tothe holding of thisCourt.in Dodez vo United States. 329 ULS. 338, 342-343, 345, 347 (19407. aS nd hae e. v ‘= . ; ‘ 3 ” Whethe ‘r the appeal! oard denied the I IF classifieation, without basis in fact contrary to Seegion 1622.4 of the Selective Services Regulations, resulting in the- 1-0 — sification being arbitrary, capricious sind contrary té law and making, the final order to do civilian work void. - \ LE Zs : Whether a waiver adthor zed by tan die retary of The Army, éxpresstly Mnited: to Siiduetion® into. the Armed ‘Forces, may he eanstrued. to. he oa Waiver a> regards eivihan employient in “te hiunicipal , ageney, > Mites - STATU TES AND REGUL ATIONS INVOLV ED "Section Ie) ‘of = Universal Military Tramuniz and Ne rvfee ” Act (50 U. . App. “451 (e )}) provides: ° 0 The ¢ ‘ongress further declares that ina free soe ‘ety the obligations and, privileges of. serving in. the ¢ arnied ~ forees.dnd the reserve components thereof, should Ve shared generally, in accordance with a system of sélee- - tion whieh is fair and Just, and whieh is ¢ onsiste nt with _ the’ maintenance ‘of an effective national economy, ~—June 24, 1948. ch. 62h, title L. 2 AY G2 Stat. 604; — June 1, 181. eh. 144, tithe E> tear) Stat. Tee Ce ate, Fae th * Seetion 6¢) of the Universal Military ‘Training and Service Net (62 Stat. G04, G12) 6222 GCF Stat. TE 86 (50 TLS.C. App. 4 j))) ix involved here, The pertinent — ane reels as follows : . a ‘ “Nothing contained im? this title hall he ern to require ‘whe person té*beosubject to combatant training and service in the armied toree: ‘sof the United States whe, by reason of. religious training’ and belief, _ is conscientiously opposed, to participation in war in, any form. Religions training amd belief in this connee- tion means an indiv iduat’s. Iagieet In acrelation to.aSu- preme Being involving deities superior to those arising from any human relation, but does not’include essen- tially. political, sociological, or philosophical views or | a merely pe “rsonal moral code. Any person clainiing we) Seniption from combatant training and service beeise of such. conscientious obijections Whose cain Is . —! ’ _ person cleduing exemption, from: combatant, training + tained by the local board shal; ak isp indueted “inte the 3 armed forees under this sy Po eee hen, combatant service as defined by the President, or shall. if he is found to be éonscientious ly oppose dito parties. prition in such noncombatant serviee, in Tiew of sucl induction, be ordered Inv his loeal board, subject te s ‘such reguiations as the President may -preserihe, ts ‘perfornt for a, period equal to the period prescribed in section + (hb) such civilian work contributing ter the maintenance of the national health, safety, or interest as the local board may deem appropriate 2 * * | Any and Service ‘hee “Use: of suc Ke conse lenti (RLS objections shall, if such claim ix not sustained by the lobal bh: urd he entitled to an appeal to the appropriate appeye board. Upon4he filing of such appeal, thie appeal boar shall refer any such claim tothe De ‘partnrent of Pustice for inquiry and hearing. The Depirtment. of Jugtice, after ‘appropriate inquiry, shytl hold a hearing witi respect ta the Character and good faith of the objec- — tions of the person concermed, and. such person stall be, notified of the time and place of such hearing. The Department of Justice shall, after such hearing, if the: Objeétions are found to be sustained, reeominend, to the appeal board that, (1) af the objector is inducted inte ‘the armed fordes under this tithe: he’ shall he assigned to poncombatant service as defined By the President. or (2) if the objector is found to be conscientious! “opposed to participation in such noncembatant service, he shall in lieu of such induction, becordered by li local hoard, subject to such reguhitions ads the Pres ident niay prescribe, to apawies for a period-equal te the period) prescribed. it it section 4+ (b)- such eivitian work contributing to ang Inaintenanee of the natienal ‘health, safety. or interest as the local board may deem appropriate *** Tf atter such hearing the Departin: nt, of Justice finds that his objections are not, sustain, . . . —E ; it shall recommend te the ap Hy “atl binrit that a. . Pa More speeitie information con erning such an entry, especially with respeet- to personal backgrotnd, the cireumstanees of the incident or ingidents, and tinal dis- position of charges Will be obtaimed from theeregistrant at the induetion station during the preinduction inter: view. [fia waiver is granted under (1)or (2) below, a copy of the report@f investigation om whieh waiver ts’ predicate will be attached to the original copy of thie induction record (DD F orm 47). 1) prirtane nt of the Army Special IRewul itions, approved — 1) April 1953, SROLS- TSO, paar, 10d 1). “A registrant: who @has heen convicted by a eivil court, Or who has a.record of adjudication adverse to him bya juvenile court, for any offense punishable by — death or Gnprisonment fora tern exeeeding TL vear is — tnerally ynaceeptable fer service in the Armed -Forees unless sucti sie ae at len is Wauved by the respective department . . : | hartinent of the Ari Spec al Re wthaten. approved | IW April 1953. SROTOTSO-T. pars Tle: Indiv iduals inte Tiscittle for induetion. (i ie ; “Individuals. listed below are. ineligible fior ii duction.” fa a . - Ti lninistrative Disqualitieations. . . Se | («) Registrants Who fail te peer the preseribe ad moral ’ ber 16, 1958, the appellant reaffirmed his position. .The “next day, the Local Board determined that employment as an institutional helper at the Los Amgeles County Depart- ae = 18 ment ef Charities would: be appropriate for the appellant, and requested. authority to order him to work.there. The? Director of the Selective Service System approved this re- quest on October 3, 1997, The letter of transmittal of this authorization from the State Director to the Local Board reads in part as follows: | ee “A copy of the letter of instructions to the registrant should’ be mailed to the agency selected at least. four days in advance of the date set for the registrant to report to the office.” | . The appellant's file contains the report of an interview with the appellant on September ‘16, 1957, atthe Local Board, at which time the appellant stated that he could not. accept any job affered by Selective Sérvice in lieu of indue- tion,’ although he did admit that he was not a pioneer min- ister, and worked forty’ hours a wéek ‘in secular employ- ment. » “# y , On October 9, 1957; the appellant was-ordered to report for civilian work to his Local Board, on October 21, 1957. to be given instructions.to proceed to the: Los Angeles County Department .of Charities. As has.already. been stated, it was stipulated that thesappellant did nokso report. The appellant seems to attach some jmportance to the concluding ‘paragraph of his “Statement of the Case”: “In“the entire Selective Service file, there is only one document that indicated any action by the Los Angeles _ -— County Department of Charities. This is. the statement * of employer found on the-bottoM of the aforesaid order - to report-for civilian work. Th¢ only notation on this un- dated statement isthe typewpitten phrase ‘DID NOT REPORT.” 1 shee The Court is at a loss as to why counsel regards the _ Ina letter to the Local Board on August 25, 1957, the appellant said that ‘if he Were to accept work prescribed by Selective Service, he would be serving two masters, and therefore could not accept any types of work offered. keiths OQ 4 « {i9 ‘ & ‘ ; above paragraph as worthy not-only of bare incl@sion, but of empliatie inclusion in a “Statement of the Case.” It is in- corporated in the Coiftt’s present statement for whatever comfort the appellgnt may derive f rom. it. 2. THE |APPELL ANT'S “ARGU MENT. Section 6(m) of the Universal Military Training and Service Act does not provide for discretionary waivers of prior felony —oe by the Armed Forces or civilian age > wr... by the’ Secretary of the Army, expressly Jimited to induction into the Armed Forces, does not encon- pass civilian employment in a municipal agency. 4 waiver of a prior felony conviction limited by its ns to induction into the Armed Forces cannot. operate as a waiver for civilian employment in lieu of induetion.. . The appellant's 1-A classification on August 21, 1956, did not eliminate thé necessity for a waiv er r applicable to serv- ice'in lieu of induction; “ ‘ + The evidence produced at the trial was | gally , inkufi cient to suppprt the judgment of guilty. 3. THE APPELLE rs "ARGUMENT. The appellant has failed to exhaust*his’ administrative remedy. The registrant must go to the “brink” of induction before hé can raise any infirmity in his classification. In. this case, the appellant was direefed to report to the Local . © . Board on October 21, 1957, to be given instructions to’ pro- ceed to the Los Angeles County De ‘partment of Charities. The appellant did not ‘appear at the Local Board, ‘and, therefore, is in the same position as a Pegiatrant who does not appear‘at the Induction Station.- The appellant's proper élassification on his ‘annie from _ imprisonment was 4-F. On August 21, 1956, however, the appellant was classified 1-A by his Local Board. If there - Was any error in stripping the appellant of his 4-F elassifi- cation, it occurred -when he’ ‘was: classified 1: LAs and* was ° ~~ 20 waived by his failire to appeal. In addition, the appellant . further made ‘clear this waiver by appealing his 1-O ¢lytssi- ‘fication’on the sole ‘ground that he was a minister of reli- gion. The orderly administration of the Sélective Service ‘laws prevents a registrant from bringing any flaw im his classification to the’ notice of the court trying him, where no hint of such infirmity was presented to the Local Boards. The 4-F Classification on conviction is not created for the benefit of the felon. This Court has held that-where there has been a conviction of a felony, the exemption is permis- sible but not required, The 4-F classification perinissible for a registrant is not created for his benefit, it is er reated for the henefit of the armed forces. ™ ‘The whole strain of the ayipellant’s argument that he was ' wrongly ordered togyppear for service-is a classic example of a man, seeking to profit by his own wrong. -This Court has decided that. the military authoritées are - entrusted with the task of Selecting “personnel to defend the ‘United States, and if they believe that a registrant would ‘not be suitable because of his prior felony convictiog, they are not required to take him. They may, however, waive the disability and in such instances he may be inducted into the armed forces or assigned to work of national impor- tance. No further waiver, by the Lee Angeles County Director of Charities, was necessary in — case. 4; THE APPEL LANT HAS FAILED TO EX- HAUST HIS ADMINISTR. ATIVE REMEDY: Hk tab ST GO TO THE “BRINK.” We hav e seen that the appellant was ordered to re port - for civilian work to his ‘Local Board on Oetober 2t, 1957," to be given instructions to proceed to’ the Los Angeles County Department of Charities. It has been stipulated that he did not so report. In, other words, the appellant failed to exhaust his ad- iinistrative remedies: He failed to go to the “brink.” Ne - "¢ P ‘ : ; 21 In the ieadine case of Palbo' v. U nited § States, 1944, 320- 1. S..549, 552-554, the Court said: * “The registrant may contest his classification’ be a personal appearance before the local board, and if that board refuses to alter the classification, by carry- . ing his case to.a board ‘of appeal, and thence, in cer- “tain circumstances, to the President. Only after he has exhausted: this procedure is a protesting registrant ordered?to report for service. If he has been classified for military service, his local board orders him’ to report for induction into the armed forces. If he has been classified a conscientious objector opposed to non- combatant military service, as Wag petifioner, he ulti- mately-is ordered by the local poe Som for work ° of national importance. /n each case the registrant is under the same obligation to obey tite order. But in neither case is the order to report the equivalent of acceptance for service. Completion. of the functions of the local board and appellate agencies, important as . are those functions, is not the end of the selective serv- ice progess. The selectee may still be rejected at the - induction center and. the é¢onscientious objector who is ‘opposed to noncombatant duty may be rejected at the civilian public ‘service camp. The connected series of steps into’ the national service whic h begins with regis- tration with the local board does not end until the regis- trant is accepted by the army, navy, or civilian public service camp. Thus a board order to report is no.more than a necessary INTERME DIATE step an a united and. continuous process designed to raise an army” speedily and efficiently. . “In this process the local board is charged in the ‘first instance with the duty to make the classification of registrants which Congress in its complete discre- tion saw fit to authorize. Even if there were, as’ the - petitioner ‘argues,. a constitutional requirement. that judicial review must be available to test the ‘validity ») -_—— of the decision of the local hoard, it is certain that Congress was not required to provide for judicial | intervention be ‘fore final acceptance of an individual for national service. The narrow question therefore / presented by this case is: w hether C ongress has au.’ thorized judicial review of the propriety ofa board's classifieation in a criminal -prosecution for willful vio- lation of an order directing a registrant to report FOR THE LAST STEP in the xe lective process. — “We think it has not.” oe : (Emphasis supplied) - In- Estep v. United States, 1946, 527 U.S. 114, 115- 116, |] the Supreme Court put, its own gloss upon the Falbo case, supra, pointing out that i in the earlier case “we held that in | a criminal prosecution . .. a registrant could nét defend on the ground that he was wrongfully classified and was ° entitled to a statutory exemption, where the offense was a failure to report for induction into the armed forces or for work of national importance.” . . “We found,” the Supreme Court continued, “no provi- sion for judicial review of a registrant's classifieation prior to the time when he had taken all the-steps in the selective process and had _ beén finally accepted by the, armed: services.” ier |. In Wilhams v. Thited States, 9 Cir., 1953, 203 F.2d so, 88, certiorari denied, 1953, 345 U.S. 1003, we said: “Rurthermore, as the Supreme Court pointed. out in Estep v. United States, supra, the Selective Service Act requires a selectee to come to the brink of indue- tion before he may obtain a Judie ‘ial review of his el: is sification. Congress, in setting up the selective process, - sought to avoid delays from premature litigious inter- ruption. See Falbo v. United States, supra. Prior to the time when a selectee is found acceptable any injury resulting from the action of his Board hag not mate- ‘rialized, since he might be rejected: But whan the me- » 23 ment arrives to take the oath; administrative relief from injury. to his constitutional rights is not avail- able. He must then take the. symbolic ‘one step ‘Yor- ward’ which signifies that he has complied with all the steps i in the selective process. Only then vill judicial review of an alleged violation of a selectee’s constitu- tional rights by his Local Board be available. (The Falbo. case cited.): Appellant did. not comply with all th steps in the selective process, Therefore, he may not attack his claksification or the Board's dca dure. (Emphasis supplied.) * D. THE 4-F OC LASSIFI¢ ‘ATIOMON CONVICTION ‘OF A FELONY IS NOT CREATED FOR THE BENEFIT OF THE REGISTANT-FELON, BUT FOR THE BENEFIT OF THE ARM EDFORCES. * .* the instant case, a convicted felon seems to be strivi ing to profit from his own wrong. Perhaps he is laboring under the delusion that'the Classification “4-F”, in cases of this kind, is granted for the benefit of the criminal. The Court has already exploded such a fallacy. In the recent case of Korte v. ’ United tien 9 Cir., 1998, 260 F.2d 633, 637, ce wtioeari denied, 1959, 358 U.S. 928, we used the following language: ' “We conclude that Section 6(m) of the Act (50 USC A ‘Mewendie. Section 456(m)) is not a-direction on the ‘part of Congress to exempt oh training and service those persons convicted of felonies, but on the contrar - is an injunction not to defer fron \ training and service those persons who have been |convicted of misde- meanors. Where there has been & convivtion of a fel- ony, the exemption is PERMISSIBLE but isnot RE- QUIRED. The IV-F classification permissible for a registrant is not created for his be nefit, itis created for the benefit of the armed forces. The military agen- mT * See also United States v. Sutter, DC Cal., 1954, 127 F. Supp. 109, 117. 24 cies are entrusted with the task of -selectinig personne! toalefend the United States, and if they believe a regis. trant would not be suitable because of his prior felony conviction, they are not, required to take him. They may, however, waive the disability and in such instance he may be inducted into the armed forces or assigned to work of national impertance.” (Emphasis supplied) 6. THE EVIDENCE SUPPORTED THE JUDG- MENT OF CONVICTION. Finally, the appellant insists that “The evidence pro- duced at the trial was legally insufficient to support. the judgment.” Despite this insistence, however, in his discus: sion of this point the appellant merely harks back to the claim-of the lack of “any proper waiver by the Los Angeles Count¥ Department of Charities.” We have fully dise ‘ussed this subject of waiver, and need not repeat our comments here. Nor is it necessary to dwell further on the sutliciency of the evidence. What we said in Shaw v. United States, 9 Cir. 1959, 264 F.2d_118, 120, is ped duliarly applicable here : “In cases arising! tinder the Universal: Military Train- ing and Service Act, as elsewhere in the law, an appel. ‘late court ix not required to search the record with a microscope, in an yffort to find minute but harmless flaws.in the work-of administrative bodies or of the lower courts.-In the instant case, that is precisely what the appellant-would have us do. In Witmer v. United States, 348 U.S. 375, at pages 380-381, 75 S.Ct. 392, 90 L Ed, 428, the Supreme Court has admonished us that ‘It is well to reniember that it is not for the courts to sit as super draft boards, substituting their judgments on the weight of the evidence for those of thédesiz- nated agencies. Nor should they look for substantial ev1- dence’to support such determination, (Case cited.) The classification can be overturned only if it. has no basis in, fact.” ” : 7. CONCLUSION. co The appellant has failed to exhaust his administrative yemedy, He did not report to his local board, to be given in- structions to proceed to the Los. Angeles County Depart- ment of Charities. He neglected to go to the “brink.” “He did ‘not take “the last step.” The 4-F classification for conviction of a felony _is-not- a loophole for the registrant-felon, but_te—keep ‘p convicted criminals out of the Armed Forces, T his barrier, however, may be waived by the Armed Forces, but not by the ex- convict. In the instant case, the approval of :the Secretary of the Army of the request “for waiver of civil record” in the appellant's case, was suffi¢ient. No. waiver by the Los Angeles County De ‘partment of Charities was necessary. The evidence ‘amply supports the judgment of conviction. 6 . $ c Accordingly, the judgment of the Court below is affirmed. e APPENDIX B oe were ete ana : > +e UNITED STATES COURT OF APPEALS — FOR THE NINTH CIRCUIT + Deas Ea xagp Bsorsox, — a | | Appellant, Bn ane No, 16275 Uxivep Srares oF AMERICA, : 7 Appellee. Judgment, filed and entered: November 1, 1959. - Appeal from. the United States District Court fof the” Northern District of California, Southern Division. “This cause eame-on to-be heard on the ‘Transcript of — the Record from the United States, District Court for the Northern District of California, Southern Division, and was’ duly submitted. - . ‘ge consideration whereof, it is now here.ordered a ddjudged by this Court, that the Judgment of the said Dis- ~ triet Court in this cause be, and hereby is affirmed. > A. {2 o s eee Ore. ‘ . . ee ee , 3 . . + moral? ry ane — --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386420_0245%3A2. Public record. Not legal advice.