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It's hard to hold a civilian accountable to rules governed by the UCMJ. For instance, if a married civilian contractor from Blackwater went and had and affair with an Iraqi national, he could be punished under the UCMJ for adultery, and possibly be thrown in the brig (jail).
We have had past instances where a commander in chief was guilty for breaking laws under the UCMJ yet he was not punishable for said laws, even though he was the commander in chief.
So, I think there's a hard case to make for UCMJ application here.
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