In the case of Boumediene v. Bush, the Supreme Court found that foreign "enemy combatants," detained by the US military at Guantanamo Bay, had a constitutional right to petition for the writ of habeas corpus in a federal court, and that Congress had unlawfully restricted this right with the Military Commissions Act of 2006. Importantly, though, in considering the constitutional scope of habeas corpus, the Boumediene Court studied its origins in English law and portrayed habeas as having an especially important "legacy" in Anglo-American law, which supported an expansive view of federal court jurisdiction. With this approach, the Supreme Court’s emerging doctrine of "effective control" now determines territorial jurisdiction based upon the actual degree of control that the government exercises over a place or person, rather than formalistic national boundaries. In this way, Boumediene put forward a more functional approach to assessing habeas jurisdiction.