"Quirin" had held that extant legislation authorized the use of military commissions for the types of offenses in question. While in "Quirin" there had been a public law passed with the title "declaration of war" and three Articles (15, 81 and 82) of the Articles of War, President Bush's claim relied on a congressional Joint Resolution used as a formal declaration of war (which has no precise legal definition in the United States) under the War Powers Resolution, and two provisions of the Uniform Code of Military Justice, the successor to the Articles of War.