are not exclusively American constitutional ideas but, rather, part and parcel of the global human rights movement" Koh has traced the influence of decisions from foreign courts throughout the history of the U.S. Supreme Court and the American court system. Critics of this approach argue that citing foreign decisions as legal precedents threatens American sovereignty and "lends itself to manipulation." Other commentators have observed that the "use of such nonbinding sources to bolster legal arguments is a central and uncontroversial tenet of the American judicial process." On May 12, 2009, the Senate Committee on Foreign Relations voted 12–5 in favor of Koh. After a hold was placed on his nomination, Senate Majority Leader Harry Reid announced on June 22, 2009, that he would invoke cloture on the nomination. On June 24, 2009, the Senate voted 65–31 to end debate on the nomination, paving the way for a full Senate vote the following day. The following day, Koh was confirmed by the Senate in a 62–35 vote. While working in government, Koh took a leave of absence from Yale Law School. Views on targeted killing In a March 2010 speech, Koh voiced his strong support for the legality of targeted killing by aerial drone strikes in Pakistan, Yemen, and other countries included by the U.S. government as being within the scope of the war on terror. The State Department's legal adviser said that "U.S. targeting practices, including lethal operations conducted with the use of unmanned aerial vehicles (UAVs)", which the Obama administration has leaned on heavily in its efforts to eliminate al-Qaeda and other terrorist groups in Asia, "comply with all applicable law, including the laws of war", citing the principles of distinction and proportionality. He said that the U.S. adheres to these standards, and takes great care in the "planning and execution to ensure that only legitimate objectives are targeted, and that collateral damage is kept to a minimum." He said the U.S. is in "an armed conflict with al-Qaeda, the Taliban, and the associated forces", and therefore has the lawful right to use force to protect its citizens "consistent with its inherent right to self-defense" under international law. Koh identified three elements that the U.S. considers when determining whether to authorize a specific targeted drone killing: Imminence of the threat; Sovereignty of other States involved; and Willingness and ability of those States to suppress the threat the target poses.