Mora found the brief to be "a wholly inadequate analysis of the law" and that the approved request was "fatally grounded on these serious failures of legal analysis" because it provided no bright line standard for what techniques would be prohibited; the techniques it approved "could produce effects reaching the level of torture"; and that "even if the techniques as applied did not reach the level of torture, they almost certainly would constitute 'cruel, inhuman, or degrading treatment, and either way would be unlawful.