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In Hamdan v. Rumsfeld (2006), the U.S. Supreme Court ruled that the Bush administration's use of military commissions to try detainees at Guantánamo Bay violated both the Geneva Conventions and the Uniform Code of Military Justice. Salim Ahmed Hamdan, a former driver for Osama bin Laden, challenged his detention and trial by military commission after being captured in Afghanistan. The Court found that Congress had not expressly authorized the type of military commission used, and that the Geneva Conventions applied to detainees like Hamdan, who were considered prisoners of war. This decision was a significant check on the executive branch's power in the context of the "war on terror" and the designation of individuals as enemy combatants.123

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