Following the United States Supreme Court's rulings in "Rasul v. Bush" (2004) and "Hamdi v. Rumsfeld" (2004), in which it held that foreign detainees and United States citizens had the right of habeas corpus to challenge their detention before an impartial tribunal, the Bush administration developed the process of Combatant Status Review Tribunals to serve as tribunals for the detainees. In addition, the process was to fulfill the obligation under , to determine if persons were prisoners of war or enemy combatants.