On December 30, 2004, Chief of the Office of Legal Counsel Dan Levin issued a “legal memo replacing the notorious torture guidance that had been written by [former Deputy Chief of the Office of Legal Counsel John] Yoo. Its opening line declared unequivocally: ‘Torture is abhorrent both to American law and values and to international norms.’ …Levin had excised all claims to the commander in chief’s authority to ignore laws such as the ban on torture. It also cut many of the legal defenses that Yoo had suggested could be used against charges of torture.”
– Jane Mayer, The Dark Side, Page 306