Obama Essay

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Does Obamas reliance upon lethal drones to fight Americas

ongoing War on Terror reflect a less imperial approach to
foreign policy than that of his predecessor?
Since 2001 the USA have been at perpetual war. This ongoing conflict that has
cost the US $904 billion dollars under the Bush Administration, 1 has been a real
thorn in Americas side for US foreign policy makers. Al Qaeda and later ISIS
have forced the US to act due to their ability to cause unrest in the Middle East,
something the US cannot afford to happen given that two countries of the axis of
evil, Iran and Iraq are present. Both with the potential to harbour Nuclear
weapons. The Bush administration saw a return to the imperial presidency with
the Neo conservative ideology deciding that forcing democracy on countries was
the most effective way to solve the problem.2 Bushs tendency to favour military
action over diplomacy was a result of a rather hawkish cabinet. 3 However, this
boots on the ground approach has not proved effective against an
unconventional enemy. More recently, under the Obama administration, the US
have prioritised lethal drone strikes to combat the war on terror. But does this
change in military strategy reflect a less imperial approach in foreign policy or
does the current situation facilitate the use of drones? Moreover are drones really
a less imperial state tool than the use of conventional force? To find out we need
to analyse how Obamas policy towards terrorism and form a comparison with his
predecessor.
Despite the Drone programme beginning under Bush, Obama has used them as
his primary weapon to combat terrorism and are now the preferred method of
destroying wanted targets as part of an intricate assassination programme
conducted by the CIA in conjunction with the US Air-force. 4 He has used drone
1 Lansford, Tom, Robert P Watson, and Jack Covarrubias. 2009. America's war on
terror (Farnham, England: Ashgate) pp. 14
2 Daalder, Ivo H, and James M Lindsay. 2003. America unbound (Washington,
D.C.: Brookings Institution) pp. 121
3 Lansford, Tom, Robert P Watson, and Jack Covarrubias. 2009. America's war on
terror (Farnham, England: Ashgate) pp. 65
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strikes nine times more than his predecessor. 5 The escalation in the use of UAVs
in Afghanistan, Pakistan and the Yemen represent a definitive shift in US military
strategy and fits in with Obamas preference for covert warfare. The use of
drones undoubtedly carry with them many advantages. Primarily in the context
of the war on terror they maintain superiority over their manned counterparts. 6
Drones cause less collateral damage with their strikes, are able to destroy a
target quicker than manned airstrike. For this reason they provide the president
with a very effective precise method of killing high profile suspects with minimal
effort and little ramifications. Obama in an address mentioned that the way the
US dealt with the capture and killing of Osama Bin Laden had been
unconventional and that lethal drone strikes were required to dig out terrorists in
hiding.7 In the words of the president, drone strikes only represent a part of the
counter-terrorism strategy and that when possible a tactic of detainment,
interrogation and prosecution is preferred. 8 Yet since the drone programme
gained congressional approval, over 428 strikes have been carried out resulting
in between 2439 and 3982 deaths. 9 This statistic undoubtedly contradicts the
implication that drones are used as a last result. Another study into why US
actions seem to contradict the last resort theory. Would be the case of Anwar al
Alwaki, an American citizen who was working in the branch of Al Qaeda in Yemen
and was killed by the CIA in September 2011. 10 Being an American citizen Alwaki
4 Special Order GB-73, Department of the Air Force, Headquarters Air Combat
Command, Langley Air Force Base, Virginia, 29 May, 2002
5 http://www.thebureauinvestigates.com/2015/01/07/us-drone-war-2014-innumbers/
6http://www.strategicstudiesinstitute.army.mil/pubs/Parameters/Issues/WinterSpri
ng_2013/4_Article_Hazelton.pdf
7 President Barack Obama, Remarks by the President at the National Defense
University, National Defense University, Fort McNair, Washington, DC, 23 May,
2013, in White House.gov, <http://www.whitehouse.gov/the-pressoffice/2013/05/23/remarks-president-national-defense-university> [accessed 19
March, 2015].
8 Ibid.
9 Knoops, Geert-Jan Alexander. 2014. 'Drones at Trial. State and Individual
(Criminal) Liabilities for Drone Attacks', International Criminal Law Review, 14:
pp. 44 <http://dx.doi.org/10.1163/15718123-01402004>
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had the right to a fair trial under judicial law in the US. 11 This justification being
released in the White paper document that the US could kill high members of Al
Qaeda if they were deemed an imminent threat to the US. Just for joining Al
Qaeda, according to the paper, which would mean that it didnt violate the
assassination ban.12
Another point worth considering in the context of drone
warfare is the fact that it is portrayed as an element of defensive strategy. This

assertion by the administration that it is used to combat issues that are a threat
to National Security could be used as a means to justify the use of drones as
hard power to counter a pre-emptive threat. 13
This was one of the most controversial aspects of the Bush doctrine that in the
word of George W Bush himself We will not hesitate to act alone, if necessary,
to exercise our right of self-defense by acting pre-emptively against such
terrorists.14 This underpinned and demonstrated an empowered presidency, one
that exercised its power in times of crisis. 9/11 arguably gave the Bush
administration a perfect opportunity for America to flex its military muscles and
demonstrate that it was willing to act unilaterally and at its own discretion
without the need to go through the UN. 15 This action signalled a return to the
imperial presidency. Colin S Gray argues that despite its fixation on battling Al
10 Jeremy Scahill and Glenn Greenwald, The NSAs Secret Role in the US
Assassination Program, The Intercept, 10 Feb 2014,
<https://firstlook.org/theintercept/article/2014/02/10/the-nsas-secret-role/>
[accessed 19 March 2015].
11 US Department of Justice White Paper on Drone Targeting, Lawful Use of a
Lethal Operation Against a US Citizen Who is a Senior Operational Leader of AlQaida of An Associated Force, in Lawfare.com, 4 February, 2013,
<www.lawfareblog.com/wp-content/.../020413_DOJ_White_Paper.pdf> [accessed
19 March, 2015].
12 Ibid.
13 Gray, Colin S. 2007. War, peace and international relations (London:
Routledge) pg 268
15 Gray, Colin S. 2007. War, peace and international relations (London:
Routledge) pg 269
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Qaeda in the aftermath of 9/11, The US spent most of its time fighting against
any enemy that wasnt Al Qaeda. 16 Determined to not only fight terrorist groups
but the States that harboured them meant that the US had to commit to boots
on the ground. Gray continues to argue that between 2003-2007, The US had
failed to comprehend the situation the kind of conflict to which it was
committed.17 This would suggest that it was naivety on the part of America that
it could achieve victory swiftly and with precision akin to the first Gulf War in
1991. However, they were dealing with transnational actors, those which did not
occupy territory. Conventional State warfare is therefore rendered obsolete. The
US found themselves occupying territory in the Middle East and committing
themselves. Belying the impression of their status as an empire. Colin Powell
warned that if one invades a country, liberates its people and deposes the sitting
regime, in effect, however briefly, one owns that country and must assume
responsibility for its future.18 And this was the trap that the US had been lulled
into. Not only that but it was fighting battles on multiple frontiers.
Obama has arguably reduced the US imperial influence by taking his troops out
of Afghanistan and Iraq in recent years yet he casts a two sided figure as
president. The difficulty is that Obamas speeches and addresses do not
necessarily reflect his actions abroad. As Pierre Gulain puts it: the kill list of
assassinations that Obama signs off on is at odds with his image as a liberal law
professor as his frequent resort to drones. 19 This is where the term Smart
Power coined by political theorists plays an important role in giving the illusion
of the US appearing less imperial. Obama deviates away from his predecessor
for he realises the importance of not committing to any more conflicts where
there is no clear exit strategy.20 This is the predicament he would face were he
16 Ibid. pp. 269
17 Ibid. pp. 271
18 Ibid. pp. 269
19 Gulain, Pierre. 2015. 'Obamas Foreign Policy: Smart Power
Realism and Cynicism', Society, 51: pg. 484 <http://dx.doi.org/10.1007/s12115014-9814-x>
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to put boots on the ground in Pakistan and the Yemen. Gulain argues that whilst
drones take into account the situation on the ground they do not deviate from
the general US framework of global dominance. 21 Drones are primarily used to
project power.22 Yet by attacking from the air Obama has exploited a loophole
that means the US can attack from the air with complete disregard for
international boundaries. This hypocrisy between Obamas speeches and
conflicting actions has fostered as much Anti-Americanism as the Bush
Administration. Furthermore there is the case that conducting drone attacks
creates more terrorism than it inherently destroys. 23 Drones may prevent the
nationalist backlash that the US would encounter from a terrestrial military
intervention but drone strikes still kill civilians although avoiding to do so as
much as possible.
The primary case for drones is that they are more precise than airstrikes and
therefore kill less civilians. However despite being cheaper to run they often
suffer a high casualty rate and many drones crash due to technological failure. 24
Drones primarily rely on permissible environments to be deployed which limits
their utility use. The terrain of the Middle East where they are primarily flown
allows for clear vision to the target. To add to this, the fact that the enemy does
not have sufficient air defences to disarm them. The main reason they are
effective is due to the fact that they are being used against a non-state actor. It
still begs the question whether the US would use drones for their strike capability
in a conventional conflict. Micah Zenko points out, the U.S. government has
not provided a clear explanation of how drone strikes in non-battlefield settings
are coordinated with broader foreign policy objectives, the scope of legitimate
targets, and the legal framework.25 By being deliberately vague with their use
Realism and Cynicism', Society, 51: pg. 486 <http://dx.doi.org/10.1007/s12115014-9814-x>
22 Ibid. pg 486
23 Ibid. pg 487
24http://www.strategicstudiesinstitute.army.mil/pubs/Parameters/Issues/WinterSp
ring_2013/4_Article_Hazelton.pdf
25 Ceccoli, Stephen, and John Bing. 2014. 'Explaining Divergent Attitudes Toward
Lethal Drone Strikes', Studies in Conflict & Terrorism, 38: pg. 147
<http://dx.doi.org/10.1080/1057610x.2014.981103>
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on drones and secrecy to the public they can absolutely conduct lethal
operations such as this. The other case which goes a long way in gaining
support for the use of drones is that drones seem to distance US involvement
and play on an American first policy of preventing the loss of American life. As a
result, even after the drone leaks, these strikes were still received favourably by
the American public with over 50% supporting the strikes. 26 This prioritising
drones and marketing them to the public as a way of mounting tactical assaults
without putting US personnel in harms way gets the public onside negating the
fact that despite the US not necessarily occupying territory, they still project
their power heavily. In fact the ease with which drones can be deployed has
meant that America risks imperial overstretch. Yale historian Paul Kennedy
defines imperial overstretch as the overextension either geographically,
economically, or militarily that inevitably leads to the exhaustion of vital
domestic resources, decline, and fall.27 The drone programme has made it
almost too easy to take out targets anywhere in the world. However it means
the non-commitment of a conventional force which is positive for the US
Obama is able to appear less imperial is due to the fact that the drone project
itself up until 2012 was shrouded in secrecy. 28 This cloak and justification that
secrecy is what maintains its success has allowed Obama to continually project
US power over Yemen, Pakistan and Somalia without getting into trouble. For
many years the CIA refused to confirm or deny the existence of drones being
used to perform lethal strikes.29 Even currently the specification of the Predator
and the Reaper both list a strike capability as a secondary function. 30 Very little
has been known about the drone project or indeed the intelligence that goes
26 Ibid. 147
27 Janaro, Jeff. 2014. 'The Danger of Imperial Overstretch | Foreign Policy
Journal', Foreign Policy Journal
<http://www.foreignpolicyjournal.com/2014/07/15/the-danger-of-imperialoverstretch/>
28 Cross, Alice. 2014. 'Leaked official document records 330 drone strikes in
Pakistan | The Bureau of Investigative Journalism', Thebureauinvestigates.com
<http://www.thebureauinvestigates.com/2014/01/29/leaked-official-documentrecords-330-drone-strikes-in-pakistan/> [accessed 19 March 2015]
29 Ceccoli, Stephen, and John Bing. 2014. 'Explaining Divergent Attitudes Toward
Lethal Drone Strikes', Studies in Conflict & Terrorism, 38: pg. 149
http://dx.doi.org/10.1080/1057610x.2014.981103
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behind the strikes. The drone strikes have given the CIA a more concrete
purpose in the war on terror and also help strengthen the executive branch. It
was the CIA that in 2012 called for more drones to come into service thus
expanding the drone programme. 31 Gabriel Schoenfield of the Hudson institute
reiterates that Secrecy today is one of the most critical tools of National
defence.32 It is the way that the Air Force can work under an article from the
original National Security Act of 1947 designed to cover the CIA for in their
covert operations. A legislation which allows Airforce pilots to fly the drones
under the supervision of the CIA. The secrecy of this project is again
contradictory with Obamas assertion that they should carry high transparency.
For the drone project at present violates the Freedom of information act. 33 The
advantage being that currently there is no current legal framework to charge,
with oversight, those responsible for carrying out drone strikes, 34 if indeed they
can be held responsible for war crimes, which is debatable. The drone strikes are
currently justified by several factors, primarily the Constitutional obligation by
the President to protect the country. The Administration can gain legal
authorization to carry out the drone strikes and use Bushs policies such as
AUMF, which will be discussed later, whilst ensuring that the secret nature covers
up for any controversial tactics that would imply that the operation is anything
other than defensive. The New York Times and other publications have released
evidence that supports the assumptions that the President and his underlings
resort to dubious tricks. From deliberately low balling the estimate of civilian
deaths to targeting terror suspects in Yemen whose names they do not know. 35
The pre-emptive strike method used by the administration is clearly very
30 http://www.af.mil/AboutUs/FactSheets/Display/tabid/224/Article/104470/mq-9reaper.aspx
pp. 51 <http://dx.doi.org/10.1163/15718123-01402004>
32 Kroes, R. 2014. 'The Paradox of American Global Power', Soc, 51: pp. 498
http://dx.doi.org/10.1007/s12115-014-9815-9
33 Ibid. pp. 498
pp. 43 <http://dx.doi.org/10.1163/15718123-01402004>
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imperial in its nature but by being rather more inconspicuous with their dealings
they have for the most part avoided the backlash that the Bush administration
copped for waging war with nation states. The secret nature of drone warfare
has allowed the US to fight undeclared wars on multiple fronts. 36
The resolution that both presidencies have used in their fight against terrorism is
AUMF or Authorisation for Unilateral Military Force. 37 This was passed very
quickly by congress in the aftermath of the 9/11 attacks. It was Arthur M
Schlesinger who wrote in 1973 that Presidents has a tendency to assume
sweeping powers in times of crisis.38 This in turn sees the balance of power get
completely upended with congress greatly weakened and an empowered
executive branch free to make decisions largely unchallenged. 39 This sees the
return of the imperial presidency, Bush was given reign to unleash the US
military on whomever he pleased. Since this law was passed both Bush and
Obama have used 2001 AUMF as their legal justification for the Presidents
surveillance Program, indefinite detention and virtually every use of US force to
fight terrorism across the globe in the last 13 years. 40 The interesting debate
about AUMF is that were Obama to show a less imperial approach to his foreign
35 Becker, Jo, and Scott Shane. 2015. 'Obama's Secret Kill List', New York Times
<http://www.nytimes.com/2012/05/29/world/obamas-leadership-in-war-on-alqaeda.html> [accessed 19 March 2015]
Realism and Cynicism', Society, 51: pg. 489 http://dx.doi.org/10.1007/s12115014-9814-x
37 Authorization for Use of United States Armed Forces, One Hundred and
Seventh Congress of the United States of America, 18 September, 2001,
<https://www.govtrack.us/congress/bills/107/sjres23/text> [accessed 19 March,
2015].
38 Karabell, Zachary. 2015. 'Obama: The End of the Imperial Presidency', The
Atlantic <http://www.theatlantic.com/politics/archive/2013/09/obama-and-theend-of-the-imperial-presidency/279405/> [accessed 17 March 2015]
39 Ibid
40 O'Toole, Molly. 2015. 'Obama's Dramatic Reversal On Bush's Laws Of War',
Defense One <http://www.defenseone.com/politics/2014/09/obamas-dramaticreversal-bushs-laws-war/94169/> [accessed 19 March 2015]
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policy he would surely repeal the AUMF. Yet were he to attempt to pass a similar
law through congress now it almost certainly would not be passed. Therefore it
suits the president to keep the law in place. He has not signed a law to expand
it, hes expanded it himself, and contributed to one of its most significant
expansions, to go after a new group in Iraq and Syria. 41 An expansion of this
policy demonstrates an even more imperial approach than Bush. The Obama
administration tried to manipulate the 2002 AUMF to justify drone activity in Iraq,
however the wording of that particular law is much more water tight clearly
stating use of force against Iraq, not in Iraq. 42 This tenuous link of relating ISIS
back to Bin Laden shows a clear attempt by the administration to side step
congress in order to go after the Islamic State. Administration lawyers are
unable to conclude in good conscience that the Islamic State is an associated
force with Al Qaeda.43 Use of AUMF gives a strengthened justification to use
military force not only through a presidential constitutional right. This is all
currently backed up by Article II of the constitution.
This begs the question what did Bush do wrong if Obama is still using and
expanding on his original policies at the time? Tom Lansford in his book on
Americas war on terror claims that the true litmus test of Bushs anti-terrorist
regime was whether future presidents follow the policies that Bush set up in
response to the September 2001 attacks. 44 Yes there is the case that as
mentioned previously the Bush administration was not fully aware of the threat
they were dealing with but at the same time it could be seen as complacency on
behalf of the administration. They were fully expecting a cake walk campaign
in Iraq, which simply did not happen.45 Their Global war on terror caused a huge
divide with Bush asserting youre either with us or against us. Not only did this
41 Ibid.
42 Ibid.
43 Ibid.
44 Lansford, Tom, Robert P Watson, and Jack Covarrubias. 2009. America's war
on terror (Farnham, England: Ashgate) pp.39
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breed feelings against America but it brought US imperial intentions to the fore,
something that had before been repressed. 46 The Bush administration had little
interest in pursuing a diplomatic solution and put the efficacy of force above all
else.47 The Global war on terror consumed the presidency and dictated foreign
policy. The obsession, Ivo Dalder argued brought in domestic paranoia. 48 The
Bush administration used fear not only to promote its wars and its Global War on
Terror, but also to unchain the commander in chief of an already imperial
presidency from a host of restraints.49 The actions, decisions, and policies of the
Bush Administrations uncompromising approach to the War on Terror involving
the overwhelming use of force, a rush to judgement about preemptive military
action, extraordinary rendition[s], secret detention facilities, and torture raise
serious doubts about the Administrations actual commitment to the ethical and
legal requirements of the just war tradition and international law, and thus about
the legitimacy of the war to this point.50 With this in mind, how come Obama
has not necessarily come under the same criticisms of the Bush administration?
Well, with the use of drone strikes, instead of dividing the world, the
administration has managed to use a method of targeted isolation. They are still
opening up new frontiers to fight against terrorism and still acting unilaterally
with a blanket of secrecy helping to further facilitate these actions. 51 Where the
Bush administration ultimately went wrong is that its doctrine implied that it
would use military force as a first resort rather than a last resort.
With this in mind there is a two sided argument to whether Obamas foreign
policy really is less imperial. Whilst some would argue that his seeking
congressional approval for attacks on Syria showed a weakness and sign of the
46 Ibid. 119
47 Ibid. 122
48 Ibid. 128
49 Lansford, Tom, Robert P Watson, and Jack Covarrubias. 2009. America's war
on terror (Farnham, England: Ashgate) pp.71
50 Ibid. 71
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end of the imperial presidency. 52 Others would cite Obamas actions in Libya as a
demonstration that Obama is still empowered and able to pass laws pretty much
at will. Jack Goldsmith goes even further to say that Obama has dramatically
expanded the notion of when Presidents can use force without permission. 53
There are many clues as to this continuation of imperial presidency. The US still
maintains over 1000 military bases over the world. 54 This includes those that
nation states are aware of as well as secret airbases used to deploy drones. The
fact that the US still has bases on the ground in these countries suggests that it
has no desire to retract its global influence and power projection. Other clues
into how the US still uses its military in terms of missile strikes also gives reason
to believe that the US is still very much an imperial institution. Republicans
believe that Obama in his use of unilateral action to circumvent congress
actually goes further than his predecessor in this regard. Ted Cruz, a Republican
senator, believes that Obama has a distinctive habit or pattern for disregarding
written law, instead enforcing his own policies by executive fiat. 55 Obama states
himself that The President does not have power under the Constitution to
unilaterally authorize a military attack in a situation that does not involve
stopping an actual or imminent threat to the nation. 56 Yet Goldsmith once again
claims that his words are deeply at odds with his actions. 57 Obama used article
52 Karabell, Zachary. 2015. 'Obama: The End of the Imperial Presidency', The
53 Friedersdorf, Conor. 2015. '3 Ways Obama Expanded War Powers Well Beyond
George W. Bush' <http://www.defenseone.com/ideas/2014/11/3-ways-obamaexpanded-war-powers-well-beyond-george-w-bush/98477/> [accessed 19 March
2015]
54 Kroes, R. 2014. 'The Paradox of American Global Power', Soc, 51: pp. 494
http://dx.doi.org/10.1007/s12115-014-9815-9
55 Cruz, Ted. 2015. 'The Imperial Presidency of Barack Obama', The Wall Street
Journal
<http://www.wsj.com/articles/SB10001424052702304632204579338793559838
308> [accessed 19 March 2015]
56 Ibid.
57 O'Toole, Molly. 2015. 'Obama's Dramatic Reversal On Bush's Laws Of War',
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II of the Constitution which states that the President shall be commander in chief
of the Army and Navy of the United States, and of the militia of the several
states, when called into the actual service of the United States to justify war on
Libya. He has managed to sidestep the War powers resolution dictating how long
a president can wage war without congressional permission in his conduct of
airstrikes.58 The reason being that waging war on Libya was a purely
humanitarian mission and therefore didnt count as hostilities. Moreover by
assessing who was in Obamas early cabinet and his appointments of hawkish
figures such as Stanley McChrystal some would say demonstrated an
administration going for broke, a mantra of killing by any means becoming the
norm.59 This assumption that Obama is abusing power though or is going further
than his predecessor is dismissed however by less conservative writers. Ryan
Cooper believes that the imperial presidency is a bi-partisan affair of which
George Bush is still a major culprit. 60 After all Obama has merely used the
original policies set out by the Bush administration and expanded them. 61
George Bush did start the assassination programme.
In conclusion it would appear as though Obamas foreign policy does appear less
imperial on the surface. He is not occupying any territory and it present is slowly
retreating from the Middle-East. The Global political environment at present
means that the administration must factor in the actions of other nation states
when conducting foreign policy to maintain a regional stability in areas of
interest. And yet with Obamas use of undercover and covert force he is still
projecting US power in as aggressive way as ever. The targeted assassination
58 Friedersdorf, Conor. 2015. '3 Ways Obama Expanded War Powers Well Beyond
2015]
60 Cooper, Ryan. 2015. 'The Hilarious hypocrisy of Republicans complaining
about the Imperial presidency', The Week
<http://m.theweek.com/articles/441926/hilarious-hypocrisy-republicanscomplaining-about-imperial-presidency> [accessed 19 March 2015
61 Ibid
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programme still promotes the use of pre-emptive force put forward by the Bush
Administration. But in preferring a less conspicuous method of maintaining
military supremacy Obama has managed to give the impression of a less
imperial presidency. The ease of deployment of drones anywhere in the world
allows for the US to still maintain an omnipresence without the commitment of
boots on the ground. This also allows for swift retreat of the UAVs without having
to having to commit to rebuilding political structures such as was seen in the Iraq
war. In this respect Obama does have an exit strategy but chooses not to use it
to continue his Global war on terror. His continued use of his predecessors
policies and his willingness to expand them to further the war on terror is a
definite indication that Obamas foreign policy is still very imperial. The main
factor which underpins all of the above is the secrecy of the regime. The use of
drones relying on secrecy which is permitted by the National security act to be
used by the CIA is what gives the president so much freedom in where and when
he can choose to deploy them. By not having to invade a country directly it
further strengthens National security. The drone programme provides the
president, in this current climate, with a convenient solution to target terrorists
without endangering US life or getting involved with diplomatic negotiations with
other nation states. UAVs have allowed Obama and his administration to pursue
a more concealed, noises off, imperial presidency.
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53713&uid=60&uid=3 [Accessed 19 March 2015]
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Does Obamas reliance upon lethal drones to fight Americas

Another point worth considering in the context of drone

warfare is the fact that it is portrayed as an element of defensive strategy. This

US Department of Justice White Paper on Drone Targeting, Lawful Use of a Lethal

President Barack Obama, Remarks by the President at the National Defense

Gulain, Pierre. 2015. 'Obamas Foreign Policy: Smart Power Realism

Knoops, Geert-Jan Alexander. 2014. 'Drones at Trial. State and Individual

O'Toole, Molly. 2015. 'Obama's Dramatic Reversal On Bush's Laws Of War',

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