True, America had ratified (in 1988) the Convention against Torture, but that applied only to acts carried out on American soil, they said. And though America's own 1994 federal statute against torture did cover acts by Americans abroad, this applied only to full-blown torture, not lesser abuses. In the notorious "torture memos" drawn up by the Department of Justice and the Pentagon in 2002 and 2003, the same lawyers sought to restrict the normal definition of torture "severe pain or suffering" to extreme acts equivalent to "serious physical injury, organ failure, or even death". Not until the Supreme Court's ruling in Hamdan in 2006 did the administration accept that all detainees, wherever held, were protected by Common Article 3 of the Geneva Conventions, which bans all forms of cruel, inhuman or degrading treatment as well as torture. Within U.S. history torture has both benefited as well as a huge constraint that has affected us greatly and will keep adding on to our