Following the release of the CIA documents, Philip Zelikow, a former State Department lawyer and adviser to then-Secretary of State Condoleezza Rice, said that in 2005, he had written a legal memo objecting to torture. In it he argued that it was unlikely that "any federal court would agree (that the approval of harsh interrogation techniques) ... was a reasonable interpretation of the Constitution." He claimed that the Bush Administration had ordered all copies of his legal memo be collected and destroyed.