On Petition for a Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit, Brief of Amici Curiae, International Human Rights Organizations in Support of Respondent
- "International law places strict limits on the power of states to detain individuals. Detention cannot be arbitrary and must serve a legitimate purpose. Thus, detention without charge, with no right to bail, and where the detainee poses no flight risk or danger to the public violates international law."