Criticism also came from the governments of many countries, notably from many on the United Nations Security Council, who argued that the war broke international law. (Article VI of the U.S. Constitution states that ""...all Treaties made, or which shall be made, under the Authority of the United States, shall be the supreme Law of the Land..."" and that ""...all executive and judicial Officers, both of the United States and of the several States, shall be bound by Oath or Affirmation, to support this Constitution..."", while Article III states that the judicial power of the US Supreme Court extends to ""all ... Treaties made"". This makes a violation of international law also a violation of the "supreme Law of The Land" of America, and withholds immunity from government officials, including the president.) See Worldwide government positions on war on Iraq and The UN Security Council and the Iraq war. For its part, the U.S. administration soon presented a list of countries called the coalition of the willing which supported its position. A later aspect of the criticism has been the death toll in Iraq; over 100,000 Iraqi civilians and 4000 U.S. soldiers have been killed since the beginning of the war mainly during the ensuing insurgency and civil war. In 2004, public assertions by Bush's former Secretary of the Treasury Paul O'Neill and counter-terrorism expert Richard Clarke raised questions about the credibility of the Bush administration's pre-war claims. Both presented evidence that questioned how focused the Bush administration was on combating Al-Qaeda (which was operating out of Afghanistan, not Iraq) before September 11. Specifically, O'Neill presented classified and unclassified documents indicating that planning for a war with Iraq and the subsequent occupation began at the first National Security Council meeting and continued with each meeting. Clarke presented testimony and witnesses concerning how Bush and much of his cabinet tried to find excuses to attack Iraq immediately after September 11, such as associating it with September 11, claiming that Saddam Hussein possessed weapons of mass destruction, and claiming that Iraq posed an imminent threat, which implied that a war against Iraq would be legal by Article 51 of the U.N. Charter.