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Ange v. Bush

United States District Court for the District of Columbia
752 F. Supp. 509 (1990)


Michael Ray Ange (plaintiff) was a sergeant in the National Guard. In 1990, President George H. W. Bush (defendant) issued an order deploying Ange’s National Guard unit to the Persian Gulf in connection with the United States’ response to the Iraqi invasion of Kuwait under President Saddam Hussein. Ange brought an action in federal district court seeking a preliminary injunction that would require Ange to be returned to the United States. Ange claimed that the deployment order exceeded President Bush’s authority under the War Powers Clause of the United States Constitution and the statutory War Powers Resolution. Ange asserted that his claim was ripe for adjudication because President Bush had threatened to attack Iraq within a short time and had claimed that he could launch an attack without Congress’s consent. Bush moved to dismiss Ange’s action, and both parties cross-moved for summary judgment.

Rule of Law


Holding and Reasoning (Lamberth, J.)

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