A US Army private charged over a massive leak of government secrets claims his harsh pre-trial treatment during nine months in a military prison was directed from high up the chain of command and warrants dismissal of the entire case, according to documents.
The 110-page motion alleges Private Bradley Manning developed a rash from being forced to sleep beneath a stiff suicide-prevention blanket and suffered an anxiety attack due to harassment by guards.
The documents released by his civilian lawyer David Coombs repeat claims that Manning was forced for several days to surrender all his clothing at night and stand naked in his cell for roll call. For several days in January last year he was forbidden to wear his glasses and forced to strip down to his underwear during the day, the motion says.
The Defence Department has said Manning's treatment properly conformed to the "maximum custody" or "prevention of injury" classifications in which he was held in Quantico, Virginia, from July 29, 2010, to April 20, 2011, when he was moved to medium-security confinement at Fort Leavenworth, Kansas.
Manning's lawyers claim there was no legal or medical justification for the harsh restrictions, and that his custody status contradicted the recommendations of multiple psychiatrists.
Manning's lawyers intend to have him give evidence about his Quantico experience during a hearing on October 1-5, according to the document. Manning has not yet taken the stand during seven months of pre-trial courtroom proceedings in his court martial.
In an accompanying summary, Mr Coombs wrote that he recently became aware of emails revealing that the officer who ordered the restrictions was acting on orders from an unidentified three-star general.
Mr Coombs wrote that in a January 2011 meeting of multiple Quantico officers, an unidentified senior officer ordered that Manning be held in maximum custody or injury-prevention status indefinitely.
When a psychiatrist voiced concern about the lack of any medical basis for the order, the senior officer said: "We'll do whatever we want to do," Mr Coombs wrote.
Manning faces 22 charges for allegedly sending hundreds of thousands of diplomatic cables and war logs to the secret-spilling website WikiLeaks while working as an intelligence analyst in Iraq. Manning could be sentenced to life in prison if convicted of the most serious offence, aiding the enemy.