In the spring of 2004, the world discovered that prisoners held in Abu Ghraib prison, just west of Baghdad, Iraq, were being mistreated and tortured by U.S. personnel. In the midst of the resulting scandal, a document that has become known as the Bybee Torture Memo came to light. The memo, dated August 1, 2002, carries the official name “Standards of Conduct for Interrogation under 18 U.S.C. §§2340–2340A.” It was written by the Office of Legal Counsel of the Justice Department and addressed to Alberto R. Gonzales, who was then counsel to the president. The stated purpose of the memo was to set forth the views of the Office of Legal Counsel regarding the standards of conduct to be followed by U.S. interrogators under the international Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, as implemented through the U.S. Code.