No, but your problem here is you wish to apply today's standards to Lincoln's Union without applying those same standards to Davis' Confederacy.
Why is that?
Indeed, you insist that Davis be judged by no standards except his own, while Lincoln must be condemned by whatever cockamamie nonsense you can devise.
The important fact is that in all early phases Confederates were the aggressors and Union authorities merely responded with the goals of first preserving the Union and in due time replacing the extant system of chattel bondage with something more consistent to our declared 1776 ideals.
Weren't Davis' Confederacy "rebels"? Why on earth would you expect them to follow the law?
No, what you are trying to do is to claim that "Because the rebels broke the law, it's okay for Lincoln to break the law."
You are trying to justify Lincoln abuses by claiming criminals he was fighting didn't obey the law.
You want to employ this tactic because you really really have no justifiable argument as to why Lincoln was breaking these laws other than "they did it too!" (Argumentum tu quoque.)
in due time replacing the extant system of chattel bondage with something more consistent to our declared 1776 ideals.
Funny how you get this "Penumbra" of freeing slaves out of the Declaration of Independence, but deliberately ignore the actual words that say people have a right to abolish an existing government and form one more to their liking.
Why are your imagined 1776 ideas about freeing slaves more important than actually articulated ideas about a right to independence?
How do you pick your imaginary 1776 values over the real 1776 values of right to independence?
It's called the "Declaration of Independence." It is not called the "Declaration of freeing slaves."