Mohammed Abdullah Taha Mattan v. Barack H. Obama, 2014 U.S. Dist. LEXIS 49967

Ahmed Adnan Ahjam, a Syrian national detained at Guantanamo since 2002, was designated a "transfer candidate" by the 2009 Guantanamo Review Task Force but was not "cleared for release."
The Task Force process directed diplomatic efforts to negotiate transfers; the report explained transfers are discretionary, lengthy, and dependent on foreign-state cooperation.
FY2011–FY2013 NDAA provisions conditioned funding for detainee transfers on detailed certifications to Congress; the FY2014 NDAA replaced those certifications with a Secretary of Defense "determination" requirement and a 30-day congressional notice requirement.
Ahjam moved for partial summary judgment seeking declarations that the NDAA transfer prerequisites (2013 certification and 2014 determination provisions) unconstitutionally intrude on the President's foreign-affairs authority and that the NDAA is a bill of attainder.
The government maintained the FY2014 criteria track Executive considerations and would not independently bar Ahjam’s transfer; the district court found Ahjam lacked standing to pursue the separation-of-powers challenge and rejected the bill-of-attainder claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ahjam has standing to challenge NDAA transfer-certification/determination provisions as unconstitutional intrusions on the President's foreign-affairs power	Ahjam contends the statutory prerequisites diminish his constitutional "right to be free" by creating procedural obstacles (e.g., 30-day notice) and thus cause a concrete injury	Government argues Ahjam has no legally protected interest in transfer; transfer is discretionary foreign-affairs/pardon-like executive action and any procedural rule is speculative or parallel to Executive standards	Court: Ahjam lacks Article III standing—no judicially cognizable liberty interest in transfer; harms alleged are speculative and rooted in discretionary executive foreign-affairs decisions
Whether the FY2014 NDAA (and related transfer restrictions) constitute an unconstitutional bill of attainder	Ahjam argues the statute inflicts punishment on identifiable detainees without trial	Government argues transfer/notification provisions are regulatory, not punitive, and apply generally to detainees	Court: Not a bill of attainder; military detention and statutory transfer restrictions are not punitive under controlling precedent

Raines v. Byrd, 521 U.S. 811 (standing requires actual case or controversy)
Whitmore v. Arkansas, 495 U.S. 149 (standing and case-or-controversy principles)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (injury-in-fact, traceability, redressability)
Boumediene v. Bush, 553 U.S. 723 (habeas rights of Guantanamo detainees)
United States v. Curtiss-Wright Export Corp., 299 U.S. 304 (presidential primacy in foreign affairs)
Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (executive power framework)
Johnson v. Eisentrager, 339 U.S. 763 (deference in foreign-affairs/detention contexts)
Connecticut Bd. of Pardons v. Dumschat, 452 U.S. 458 (executive clemency/commutation discretion)
Summers v. Earth Island Inst., 555 U.S. 488 (procedural-rights injuries insufficient without concrete interest)
United States v. Lovett, 328 U.S. 303 (bill of attainder doctrine)
United States v. Brown, 381 U.S. 437 (separation-of-powers purpose of attainder clause)
Selective Service Sys. v. Minnesota Pub. Interest Research Grp., 468 U.S. 841 (attainder requires punishment)
Ali v. Obama, 736 F.3d 542 (military detention of enemy combatants is nonpunitive)
Kiyemba v. Obama, 605 F.3d 1046 (statutory restrictions on transfers not legislative punishment)