“[A]fter the significant rejection [on June 29, 2006] by the Supreme Court in Hamdan v. Rumsfeld of the Bush administration’s claim that common Article 3 [of the Geneva Conventions] does not apply to detainees captured during armed conflicts in Afghanistan and Iraq and held at Guantanamo, Deputy Defense Secretary Gordon England issued a memo requiring compliance with common Article 3 by U.S. military personnel as of July 7, 2006.”

 – Jordan J. Paust, Beyond the Law, Page 42