James Crisfield, Legal sufficiency review of Combatant Status Review Tribunal for Detainee ISN 940… (2005)
“ The subject tribunal determined by a vote of 2-to-1 that the detainee was properly classified as an enemy combatant. In an articulat and thoughtful dissent, one of the tribunal members opined that the Unclassified Summary of Evidence was deficient because it failed to present a prima facie case that the detainee is an enemy combatant. [1] The Unclassified Summary of the Evidence is not intended to be a charging document that alleges each and every fact necessary to establish that an accused has committed a crime. ”
