Concurring separately, he argued for a broader definition of due process, decrying the Court's willingness to permit "selective departure[s]" from the "scheme of ordered personal liberty established by the Bill of Rights" in other cases. Rutledge's dissent in Ahrens v. Clark demonstrated what Ferren characterized as his "continued impatience... with procedural rules barring access to the federal courts". The Court in Ahrens ruled 6–3 that German nationals seeking writs of habeas corpus to stop their deportations could not lawfully sue in federal court in the District of Columbia. Aided by his law clerk John Paul Stevens, Rutledge dissented, concluding that the court in the District of Columbia had jurisdiction because the person having custody over the prisoners—the Attorney General—was located there. He argued against what he viewed as "a jurisdictional limitation so destructive of the writ's availability and adaptability to all the varying conditions and devices by which liberty may be unlawfully restrained". Stevens later served on the Supreme Court himself; in his majority opinion in Rasul v. Bush, he cited Rutledge's Ahrens dissent to conclude that federal courts had jurisdiction over suits brought by detainees at Guantanamo Bay. Rutledge maintained that the provisions of the Bill of Rights protected all criminal defendants, regardless of whether they were being tried in state or federal court. He dissented in Adamson v. California, in which the Court, by a vote of 5–4, held that the Fifth Amendment's protection against forced self-incrimination did not apply to the states. Joining a dissent written by Murphy, he agreed with Justice Black's position that the Due Process Clause incorporated the entirety of the Bill of Rights, but he went further than Black to suggest that it also conferred additional due process protections not found elsewhere in the Constitution. In another incorporation dispute, Wolf v. Colorado, Rutledge dissented when the Court ruled 6–3 that the exclusionary rule—the prohibition against using illegally seized evidence in court—did not apply to the states. He joined a dissent by Murphy and penned a separate opinion of his own, in which he argued that, without the exclusionary rule, the Fourth Amendment prohibition of unlawful searches and seizures "was a dead letter". Rutledge's dissent was eventually vindicated: in its 1961 decision in Mapp v. Ohio, the Court expressly overruled Wolf. Wartime cases In re Yamashita In the 1946 case of In re Yamashita, Rutledge rendered an opinion that was later characterized by Ferren