Making Or Breaking A War: An Analysis Of Definitions & Nomenclature In The War On Terror

De-fine, -verb; 1. To state or set forth the meaning of.

2. To determine or fix the boundaries or extent of.[i]

Just weeks after the attacks of September 11th, President George W. Bush, in a meeting with President Megawati of Indonesia, remarked the following of the coming conflict against the perpetrators of the attacks: “The mind-set of war must change. It is a different type of battle. It’s a different type of battlefield. It’s a different type of war.”[ii] Ultimately, this would prove to be true. The United States was facing a different kind of enemy; an enemy not clearly defined by state affiliation or even physical characteristics. Within this new type of conflict, it became apparent that new definitions and nomenclature must be brought into use, not only to adequately define the boundaries of the coming conflict, but also to shape public opinion.

By analyzing various new definitions (such as detainee, or unlawful combatant) and nomenclature (such as Operation Infinite Justice and The War on Terror) following September 11th, as well as the changing public perception of these terms and names, this article will etymologically examine how, following September 11th, the Bush administration used such definitions/nomenclature for immediate purposes (i.e. garnering public opinion; protecting itself legally). By not looking ahead to the long-term effects of the use of such definitions, public opinion became aware of the purposeful and hidden use of such definitions, especially amidst the controversial Iraq War. This culminated in the reversal of many such nomenclatures and definitions by the Obama administration. In short, the Bush administration, by using shortsighted definitions, set itself up for long-term failure to grasp public support in its so-called “War on Terror.”

To begin an analysis on the various controversial definitions of the “War on Terror,” perhaps it is appropriate to begin with the name of the conflict itself. On September 20th, 2001, President Bush addressed the nation, remarking that the attacks just weeks before constituted “an act of war” against the country.[iii] Thus, at this moment, the President made it clear that the conflict ahead would in fact be defined as a war – a “War on Terror.”[iv] But, considering the destruction caused on September 11th, was this definition a misstep?

As one journalist noted following the address, the President’s “approval ratings and public support for military retaliation for last week’s attacks are high,” and that the President “is keen to forestall any criticism of inaction.”[v] In a sense, the President had little room not to define the conflict as a war, or to invoke action abroad. As a lawyer working under the Bush Administration, Jack Goldsmith argued that there existed legal rational behind using the term “war,” as opposed to “struggle” or “conflict.” “The most obvious” reason, Goldsmith asserted, was the legal “power to kill any soldiers with impunity.”[vi] In short, the Bush Administration used the term “war” to create public opinion, as well as protect itself legally, as many presidents had previously done during wartime. But what were the public and long-term pitfalls of defining the conflict as a war?

In her article “Four Reasons to Use the War Metaphor with Caution,” released days after the “War on Terror” had been announced, Dr. Jayne Docherty argued the inherent dangers in using war as a metaphor. One such danger is the assumption that if a conflict is a war, “we imply that war can bring our enemies to their knees,” or that the war will eventually come to a finite end.[vii] Furthermore, Docherty argued that if “we describe this [the War on Terror] as a war, we betray our own highest values of justice, due process, and fairness; criminals are granted rights that enemies in war are denied.”[viii] Hence, in calling the struggle in Afghanistan a “war on terror,” the Bush administration essentially put itself into a corner. In using the nomenclature “War on Terror,” the administration implied that the war would be easily and victoriously won, an idea that brings about controversy ten years later. In a recent look at the war in Afghanistan, CNN proclaims, “As the Afghanistan war enters its ninth year…commentators are asking: When does it end?”[ix] In addition, as will be seen later in this article, the Bush Administration created a disparity between affording the laws of war to terrorists and the actual status applied to prisoners.

Another key component in the downfall of shortsightedly using the war metaphor can be found in the same address to the nation in which the war metaphor was offered. As President Bush stated, “al Qaeda is to terror what the mafia is to crime.”[x] With this sentence and the war methaphor, the president had, perhaps unintentionally, but nevertheless, linked in the long-term, the War on Terror to the War on Crime and War on Drugs and even the failed War on Poverty.

By relating these “wars,” the ensuing conflict in Afghanistan invokes ideas of billions of dollars in taxpayer money[xi] and so-called “wars” which have lasted for more than thirty years without bringing an end to crime or drug use. And as another war in the Middle East became a growing prospect, many began to question the effectiveness of the initial “war on terror” in Afghanistan. As one editorial in The New York Times noted, using the phrase “war on terror” is akin to describing “campaigns against social evils like alcohol, crime and poverty – endemic conditions that could be mitigated but not eradicated.” The author added, “Society may declare a war on drugs or drunken driving, but no one expects total victory.”[xii] Coupled with the President’s unrealistic goal of defeating “every terrorist group of global reach,”[xiii] the relation to the war on drugs and war on crime was only strengthened. And in a country that is fond of short, inexpensive wars, the war metaphor in relation to the conflict against terrorists was doomed from the beginning.

Ultimately the eventual failure of using the war metaphor in relation to the conflict against terrorists can be seen today. As one Time Magazine article noted during the 2008 presidential elections, the phrase “War on Terror” “is being regarded with hostility by many Democrats, who view it as little more than propaganda.” The article further noted that even Conservatives treat the phrase with “skepticism” and considered it “tired and vague.”[xiv] Even President Bush (albeit jokingly) realized the downfalls of using the war metaphor, in his remarks to the UNITY Journalists of Color Convention: “We [the Bush Administration] actually misnamed the war on terror, it ought to be the struggle against ideological extremists who do not believe in free societies who happen to use terror as a weapon to try to shake the conscience of the free world.”[xv] While dizzily ridiculous, the name actually described the conflict quite accurately.

As President Obama assumed office in 2009, policy-makers under the president began using the phrase “Overseas Contingency Operation” instead of “War on Terror.”[xvi] And during the 2010 commencement ceremony at West Point, President Obama remarked of the conflict against terrorists, “There will be no simple moment of surrender to mark the journey’s end – no armistice, no banner headline.”[xvii] Thus, in the years since September 11th, 2001, public opinion began to realize the downfalls of using the metaphorical nomenclature, and turned against defining the conflict against terrorists as a war, culminating in the Obama Administration distancing itself from the war metaphor. But what caused this change in public support?

As has been shown, the war metaphor conjures, on an immediate level, a swift and victorious war, yet, in the long term, a costly, drawn-out, and ineffective war. Thus, when the U.S. began preparing for a second war in the Middle East, the public (and the administration itself) began to see the long-term side effect of using the war metaphor. As opposition to the war in Iraq mounted (especially after the U.S. found no weapons of mass destruction) commentators began using the term “Long War” instead of the “War on Terror.”[xviii]

Ultimately credited to General John P. Abizaid to describe the long war that faced Al-Qaeda,[xix] the term nevertheless took hold among the public in a negative sense. Even Defense Secretary Rumsfeld, amidst the Iraq War in 2005, pushed for a change in the term “War on Terror.” Arguing instead for “Global Struggle Against Violent Extremism” or GSAVE, officials claimed that the term “War on Terror” “outlived its usefulness” focusing solely “and incorrectly, on the military campaign.”[xx] Thus, only following growing anti-“war” sentiment of the Iraq War did the Bush Administration attempt to distance itself from the short-term purpose of using the term “War on Terror” in the hopes of deflecting connotations of an expensive, ineffective, and long-lasting conflict in relation to the other war in the Middle East.

Another source of controversy regarding the need to define various facets in the conflict against terrorists came about in the operational name of the conflict itself. Originally billed as Operation Infinite Justice, the name soon sparked controversy among Muslims. Believing that the name was similar to eternal retribution, and likening the United States to God,[xxi] Defense Secretary Rumsfeld swiftly changed the name to Operation Enduring Freedom. But in ending some controversy, the name change invoked more controversy.

The chief problem of the name change was the use of the adjective Enduring. The word, as one contemporary journalist pointed out, brought about the idea of a “long-lasting” war or, as a present participle, the idea, “‘how long are we going to be enduring this freedom?’”[xxii] Interviewed in the article, Robin Tolmach Lakoff, the author of The Language War, stated, “The name had to please so many different kinds of people that every adjective seemed fraught with offensive overtones.”[xxiii] In the new type of war created following September 11th, operational nomenclature held political and public importance. Again, however, in its immediate goal of creating an operational name indicative of justice, freedom, and action, the long-term effects were swept aside. In a war in its tenth year, however, the conflict against terrorists cannot help but be seen as “enduring.” But, in relation to the definitions “detainee” and “unlawful combatant,” is freedom really enduring?

One of the more unique aspects of the conflict against terrorists (and certainly the most controversial) is the Bush Administration’s definition of the prisoners of the conflict. While defining the conflict as a “War” on Terror, invoking ideas of Geneva-style prisoners-of-war, the Bush Administration argued that, in being a “different kind of war,” new laws and definitions regarding captives would be created. “Detainee” and “Unlawful Combatant” would soon enter into public use.

Just two months after September 11th, 2001, the President signed the “Military Order: Detention, Treatment, and Trial of Certain Non-Citizens in the War Against Terrorism” into existence. In section three of the order, the President proclaimed, “Any individual subject to this order shall be – (a) detained [emphasis added] at an appropriate location designated by the Secretary of Defense outside or within the United States”, and in section four, “(a) Any individual subject to this order shall, when tried, be tried by military commission.”[xxiv] This order built upon the Authorization for Use of Military Force Bill, signed on September 18th, 2001, in which the President was given the ability to “use all necessary and appropriate force against those nations, organizations, or persons [emphasis added] he determines planned, authorized, committed, or aided the terrorist attacks that occurred on September 11, 2001.”[xxv] Thus, any captive in the conflict against terrorists would be defined as a “detainee,” and not a prisoner-of-war. Within this, the President could use any “necessary and appropriate force against” anyone deemed a “detainee,” forgoing many rules laid down to protect prisoners-of-war under the Geneva Convention.[xxvi]

Essentially, the definition and idea of a detainee was a new and unique to the post-September 11th United States. While similar in nature to the forced detainment of Japanese-Americans during the Second World War, the country was not bound to any strict international law regarding prisoners-of-war or detainees - laws which were passed in 1949. Furthermore, the term was defined in order to circumvent such law, in order to quickly gain intelligence in the ensuing conflict. This idea stands in contrast to the civilian trial of known terrorist Omar Abdel-Rahman for his role in the 1993 World Trade Center bombing, exhibiting how unique the attacks of September 11th truly were.

Within the first few years following the attacks of September 11th, little attention was paid to the treatment of captives of Al-Qaeda. Many contemporary journalists and those they interviewed in fact focused on the advantages of housing detainees in an offshore facility. As a professor from Pensacola claimed when interviewed, “the selection [of Guantanamo Bay] makes sense. ‘It’s [Camp X-Ray] a logical, valid place with plenty of space and excellent security. And the military can do whatever they want to do there. At most bases, you have to have specific permission from the host country.” And in the same article, Captain Player of the U.S. Navy claimed, “holding detainees aboard ships would be more costly to American taxpayers.”[xxvii] Hence, journalists focused more on the short-term connotations of using the term detainee: the public wanted security from terrorists and governmental ability to do whatever was necessary to achieve this (and, in the American way, at a low cost). But, years later, the topic of what defined a detainee was surrounded by much debate and controversy. The question comes about - what caused this fundamental shift in public opinion?

While various newspapers printed reports of minor abuse in Guantanamo against detainees - such as the use of shackles and hoods[xxviii] - the treatment of detainees was not a hotbed issue in 2002 or 2003. This changed, however, in 2004. In April 2004, reports began surfacing of gross human rights violations among Iraqi detainees in the Abu Ghraib Prison in Iraq. Pictures of nude Iraqi detainees in piles and inhumane treatment of detainees opened the public’s eyes to the long-term effects of such wide connotations of the term “detainee.” Shortly afterwards, focus turned to the treatment of detainees at Guantanamo. In one article, a link was made between the handling of detainees at Abu Ghraib and Guantanamo.

According to The New York Times, Major General Geoffrey D. Miller, “who won praise from the Pentagon for improving the flow of intelligence from terrorist suspects and prisoners of the Afghanistan War” while commanding Camp X-Ray, made recommendations for Abu Ghraib “based in large part on his command of the detention camp in Guantanamo Bay, Cuba.” [xxix] While overtly biased, an important letter to the editor published in the New York Times never-the-less captures the festering public sentiment. “The war on terror is not a real war. This is a continuing, never-ending excuse [to] trample civil liberties in the name of ‘war.’”[xxx] Public opinion, it seemed, began to shift after fully realizing the scope of definition of the term“detainee.”

Shortly thereafter, the U.S. Supreme Court in Hamdan v. Rumsfeld, ruled that the U.S. government, in imprisoning detainees at Guantanamo Bay, had violated the writ of Habeas Corpus, as well as article three of the Geneva Conventions on the treatment of prisoners-of-war.[xxxi] In response, President Bush signed the “Military Commissions Act of 2006.” The purpose of the act was to “authorize trial by military commission for violations of the law of war, and for other purposes,”[xxxii] in effect upholding the Geneva Conventions, and, on paper, defining “detainee.” The act, however, also further defined the prisoners of the conflict against terrorism to continue to gather intelligence, despite a growing oppositional public sentiment.

In “Section 948a. Definitions” of the act, “unlawful enemy combatant” effectively replaces the term “detainee.” Unlawful combatant is defined as follows:

The term ‘unlawful enemy combatant’ means- (i) a person who has engaged in hostilities or who has purposefully and materially supported hostilities against the United States or its co-belligerents who is not a lawful combatant (including a person who is part of the Taliban, al Qaeda, or associated forces); or (ii) a person who, before, on, or after the date of the enactment of the Military Commissions Act of 2006, has been determined to be an unlawful enemy combatant by a Combatant Status Review Tribunal or another competence tribunal established under the authority of the President or the Secretary of Defense.[xxxiii]

Thus, while the Geneva Conventions regarding prisoner treatment are lawfully upheld, the act also defines the military trial an “unlawful enemy combatant” can have. In section 948b. “Military Commissions Generally,” limits are placed on military trials of terrorist prisoners. “Section 810 (article 10 of the Uniform Code of Military Justice), relating to speedy trial, including any rule of courts-martial relating to speedy trail” shall “not apply to trial by military commission under this chapter.”[xxxiv] Hence, despite shortsighted use of the term (and the ideas behind its use), the Bush Administration re-defined the term “detainee” again in shortsighted means.

As President Obama entered into office in 2009, many such definitions were again re-defined. In the early days of his presidency, President Obama, atleast on paper and in theory, closed the Guantanamo Bay facility where detainees were being held, prohibited the CIA from maintaining overseas prisons, and invalidated all legal orders on interrogations issued by any lawyer of the Bush Administration since September 11th, 2001. [xxxv] Amendments were also made to the Military Commissions Act of 2006, in which easier access to counsel and the banning of hearsay were enacted, as well as again redefining “unlawful enemy combatant” as “unprivileged enemy belligerent.[xxxvi]

In the end, the term “detainee” was used, in the short term, to lock away prisoners of the conflict against terrorists to ensure American safety. Furthermore, in defining a captive a “detainee” and not a “prisoner-of-war,” the Bush Administration was able to use whatever means necessary to gain intelligence in the continuation of the conflict against terrorists. Initially, the American public supported this; however, when the pictures and stories from Abu Ghraib entered into the public consciousness, the word detainee took on negative connotations. Public opinion was effectively altered, and controversy arose over the wide scope of the definition of detainee. In order to continue to gain intelligence, the Bush Administration simply re-defined detainee as an unlawful enemy combatant in order to appease public opinion. The damage, however, was already done. The Obama Administration again distanced itself from the Bush Administration, by redefining the captive of the conflict against terror.

As has been exhibited, following the attacks of September 11th 2001 the country entered into a conflict different from any other. In this, the Bush Administration had to define the ensuing conflict and who the enemy was. In doing so, however, the Bush Administration seemingly drafted their definitions with short-sited eyes. Nomenclature like the “War on Terror” and “Enduring Freedom” invoked ideas of swift American dominance and justice over the county’s enemies; the definition “detainee” defined how the enemies of the conflict will be treated in order continue the conflict as well as keep the country safe in the immediate future. In using shortsighted definitions, the administration was legally covering itself in the immediate time frame. In the long run however, these terms invoked ideas of a long, costly war, with little effectiveness and no end in sight, as well as human rights violations by the United States.

During World War II, President Roosevelt, like President Bush in 2001, acted in the immediate moment, using Executive Order 9066 to intern thousands of Japanese-Americans. And like President Bush, President Roosevelt used vague terminology and terms to do so. In viewing the desparity between these similar actions in history, one question arises. Why, in the “War on Terror,” has the public turned against the use of broad definitions and nomenclature?

Thus, the importance of the Iraq war in the change of public opinion cannot be understated. In his book on the legality of the War on Terror, Jack Goldsmith ended with the idea that in the public eye, President Bush was not perceived to be winning the War in Afghanistan, “in large part because of [the war in] Iraq.”[xxxvii] When viewed in the context of public perceptions of wartime definitions and nomenclature, this statement is roundly true.

As has been seen, the idea of a different kind of war (a war more akin to America’s past wars) and a controversial war fundamentally changed the public’s view of the war in Afghanistan, and its accompanying definitions and nomenclature. For it was the idea of a second war in the Middle East that caused controversy about the effectiveness of the “enduring” freedom in Afghanistan, and it was the Abu Ghraib abuse scandal, which caused the American public to focus their eyes on the true definition of a detainee. As previously mentioned, most initial dissent published about the treatment of detainees in Guantanamo Bay came from humanitarian groups, angered over the use of hoods. Abu Ghraib, however, brought light onto how a detainee is truly defined and, more importantly, why. And against the backdrop of very visual abuses in Iraq, the definition of a detainee five thousand miles away in Cuba mattered all the more.

Around the time of the Iraq War as well, an influx of terminology like “shock and awe,” and “green zone,” or the differences between a “Shiite” and a “Sunni” began to enter into public consciousness, causing several newspapers to (sometimes satirically) publish what one paper called “government-speak.” [xxxviii] Thom Shanker ran a weekly editorial in The New York Times entitled “Words of War,”[xxxix] in which every article published lists of definitions like “counterterrorism” and “terrorism.” Eventually, the public became aware of the purposeful and many times hidden aspects of the definitions of the conflict against terrorism. Definitions and nomenclature, now used in every aspect of the war, had become a joke in the public realm. Perhaps too, as these articles show, with ever increasing technology and media, the spoken word became more and more of a written one - and in doing so, evermore analyzed.

By using (and many times over-using) nomenclature and definitions to draw the boundaries of the conflict against terrorists, the Bush Administration set up the American public for dissatisfaction with the war in the long run. In using terms to generate immediate public support, but not to accurately describe the true situation of the conflict, the Bush administration created disparity that became ever more present, especially when the controversy surrounding the Iraq War exposed the long term pitfalls of using broad definitions and hasty nomenclature (though, in fairness, it is hard to say if any President would have acted differently under immense public pressure for immediate action, and such an unprecedented event).

As a Department of Homeland Security memo put forth after the fallout from the Iraq War, “Words matter. The terminology that senior government officials use must accurately identify the nature of the challenges that face our generation.”[xl] Definitions and nomenclature, espeically when used to bound an entire people or war, do just that – define; they become the representation of how the public perceives what they describe. Thus, the importance of definition and nomenclature in the public realm is fully shown; it has the ability to make or break a situation, and, as has also been shown in the post September 11th world, an entire war.



Matthew Gordon is the author of The Thin Blue Line: An In-Depth Look at the Policing Practices of the Los Angeles Police Department & To Live, To Think, To Hope - Inspirational Quotes by Helen Keller.

© Matthew Gordon, 2011

Notes

[i] “Define,” Dictionary.com, accessed November 28, 2010. <http://dictionary.reference.com/browse/define>.

[ii]George W. Bush, "President Building Worldwide Campaign Against Terrorism," Politicalvideo.org, 19 September 2001. Accessed November 28, 2010.

[iii]George W. Bush, "Address to the Nation," Presidentialrhetoric.com, 20 September 2001. Accessed November 28, 2010. <http://www.presidentialrhetoric.com/speeches/09.20.01.html>.

[iv] George W. Bush, “Adress to the Nation,” 20 September 2001.

[v]Gary Younge, "Bush Talks of a 'Different Kind of War,'" Guardian, 21 September 2001. Accessed November 28, 2010, <http://www.guardian.co.uk/world/2001/sep/21/afghanistan.september1113>.

[vi] Jack Goldsmith, The Terror Presidency, (New York: W.W. Norton & Company, 2007), 130.

[vii]Jayne Docherty, "Four Reasons to Use the War Metaphor with Caution," Mediate.com, 24 September 2001. Accessed November 28, 2010. <http://www.mediate.com/articles/Docherty.cfm>.

[viii] Jayne Docherty, “Four Reasons to Use the War Metaphor with Caution.”

[ix] John Blake, “Is American on the Path to ‘Permanent War?,” CNN.com, 24 November 2010. Accessed November 28, 2010, <http://www.cnn.com/2010/POLITICS/11/23/war.afghan/index.html>.

[x] George W. Bush, “Adress to the Nation,” 20 September 2001.

[xi]Dan Baum, Smoke and Mirrors: The War on Drugs and the Politics of Failure, (New York: Back Bay Books, 1996) VIII.

[xii]Geoffrey Nunberg, "Terrorism: How Much Wallop Can a Simple Word Pack?," New York Times, 11 July 2004: WK7. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 1058884252.

[xiii] George W. Bush, “Adress to the Nation,” 20 September 2001.

[xiv]Mike Allen, "Edwards Rejects the 'War on Terror,' Time, 2 May 2007. Accessed November 28, 2010, <http://www.time.com/time/nation/article/0,8599,1616724,00.html>.

[xv]George W. Bush, "President's Remarks to the Unity Journalists of Color Convention," George W. Bush: The White House, 6 August 2004. Accessed November 28, 2010, <http://georgewbush-whitehouse.archives.gov/news/releases/2004/08/20040806-1.html>.

[xvi]Scott Wilson and Al Kamen, "'Global War on Terror' is Given New Name," The Washington Post, 25 March 2009. Accessed November 28, 2010, <http://www.washingtonpost.com/wp-dyn/content/article/2009/03/24/AR2009032402818.html>.

[xvii]Barack Obama, "Commencement Address at West Point," Presidentialrhetoric.com, 22 May 2001. Accessed November 28, 2010. <http://www.presidentialrhetoric.com/speeches/05.22.10.html>.

[xviii]James Carafano, "The Long War Against Terrorism," The Heritage Foundation, 8 September 2003. Accessed 28, 2010, <http://www.heritage.org/Research/Commentary/2003/09/The-Long-War-Against-Terrorism>.

[xix]Bradley Graham and Josh White, "'Abizaid Credited With Popularizing the Term 'Long War,'" The Washington Post, 3 February 2006. Accessed November 28, 2010, <http://www.washingtonpost.com/wp-dyn/content/article/2006/02/02/AR2006020202242.html>.

[xx]Eric Schmitt and Thom Shanker, "U.S. Officials Retool Slogan for Terror War," New York Times, 26 July 2005. Accessed November 28, 2010, <http://www.nytimes.com/2005/07/26/politics/26strategy.html?_r=1>.

[xxi]Sarah Boxer, "Operation Slick Moniker: Military Name Game," New York Times, October 13 2001: A13. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 366619762.

[xxii]Boxer, "Operation Slick Moniker: Military Name Game," A13.

[xxiii]Boxer, "Operation Slick Moniker: Military Name Game," A13.

[xxiv]George W. Bush, "President' Issues Military Order," George W. Bush: The White House, 13 November 2001. Accessed November 28, 2010, <http://georgewbush-whitehouse.archives.gov/news/releases/2001/11/20011113-27.html>.

[xxv]"Authorization for Use of Military Force," S.J. Res. 23, 107th Congress, (2001). Findlaw.com. Accessed November 28, 2010, <http://news.findlaw.com/wp/docs/terrorism/sjres23.es.html>.

[xxvi]"Convention (III) Relative to the Treatment of Prisoners of War," ICRC, 12 August 1949. Accessed November 28, 2010, <http://www.icrc.org/ihl.nsf/COM/375-590006?OpenDocument>.

[xxvii]Katharine Q. Seelye, "U.S. to Hold Taliban Detainees in 'the Least Worst Place,'" New York Times, 28 December 2001: B6. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 367307962.

[xxviii]William F. Schulz, "The Fate Of Qaeda Prisoners," New York Times, 19 January 2002: A19. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 731121702.

[xxix]Tim Golden & Eric Schmitt, "General Took Guantanamo Rules To Iraq for Handling of Prisoners," New York Times, 13 May 2004: A1. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 1058355492.

[xxx]Bebe Brown, "Definitions of War," New York Times, 14 January 2003: A26. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 865474782.

[xxxi]Hamdan v. Rumsfeld, No. 05-184. U.S. (2006). LexisNexis Academic. Accessed November 28, 2010. <http://www.lexisnexis.com.proxy.lib.umich.edu/hottopics/lnacademic/?>.

[xxxii]"Military Commissions Act of 2006,"10. U.S.C. Section 948a (2006). Accessed on November 28, 2010. <http://www.loc.gov/rr/frd/Military_Law/pdf/PL-109-366.pdf>.

[xxxiii]Military Commissions Act of 2006,"10. U.S.C. Section 948a (2006).

[xxxiv]Military Commissions Act of 2006,"10. U.S.C. Section 948b (2006).

[xxxv]Dana Priest, "Bush's 'War' on Terror Comes to a Sudden End,'" The Washington Post, 23 January 2009. Accessed November 28, 2010, <http://www.washingtonpost.com/wp-dyn/content/article/2009/01/22/AR2009012203929.html>.

[xxxvi]"Military Commissions Act of 2009,"10. U.S.C. Section 948a (2009). Accessed on November 28, 2010. <http://www.defense.gov/news/2009%20MCA%20Pub%20%20Law%20111-84.pdf>.

[xxxvii] Jack Goldsmith, 213.

[xxxviii]Rebecca Corbett, "Give Him a Tasking and Caveat the Report," New York Times, 28 March 2004: WK5. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 1071553082.

[xxxix]Thom Shanker, "Words of War," New York Times, 30 March 2003: WK2. ProQuest Historical Library. Accessed November 28, 2010, Document ID: 866719532.

[xl]U.S. Department of Homeland Security, Terminology to Define The terrorists: Recommendations from American Muslims, January 2008: 1. The Investigative Project on Terrorism. Accessed November 28, 2010. <http://www.investigativeproject.org/documents/misc/126.pdf>.

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