In January, 2002 Alberto Gonzales wrote a memo using those terms to describe the Geneva Convention, specifically how Geneva Convention adherants should treat prisoners of war.

His memo was used by the Bush admininstration to justify torture of prisoners of war in Iraq.

Alberto Gonzales was subsequently nominated by George Bush to be Attorney General of the United States.

Nice admininstration we've got here, eh?

The Congressional hearings on the Gonzales apointment start today.