For helping to advance the process of clarifying U.S. law regarding those detained in the global war on terrorism. To be sure, the Bush administration has been slow to engage with Congress on this issue and probably still would not be doing so but for the Supreme Court's decision June 29 in the Hamdan v. Rumsfeld case. Yet, as England so clearly proved at a hearing of the Senate Armed Services Committee, the administration's arguments have great merit.

http://www.armedforcesjournal.com/2006/09/2112684