upheld the internment of Japanese-Americans, each emergency power "lies about like a loaded weapon, ready for the hand of any authority that can bring forward a plausible claim of an urgent need." Contrary to claims of some authors, the first administration to make explicit reference to the "Unitary Executive" was not that of President George W. Bush. For example, in 1987, Ronald Reagan issued a signing statement that declared: "If this provision were interpreted otherwise, so as to require the President to follow the orders of a subordinate, it would plainly constitute an unconstitutional infringement of the President's authority as head of a unitary executive branch." The George W. Bush administration made the Unitary Executive Theory a common feature of signing statements. For example, Bush once wrote in a signing statement that he would, "construe Title X in Division A of the Act, relating to detainees, in a manner consistent with the constitutional authority of the President to supervise the unitary executive branch and as Commander in Chief and consistent with the constitutional limitations on the judicial power." Critics acknowledge that part of the President's duty is to "interpret what is, and is not constitutional, at least when overseeing the actions of executive agencies," but critics accused Bush of overstepping that duty by his perceived willingness to overrule US courts. In film In the 2018 biographical film Vice, directed by Adam McKay, the unitary executive theory is explored in some detail and dramatized. Dick Cheney, the film's subject, his lawyer David Addington, Deputy Assistant US Attorney General in the Office of Legal Counsel John Yoo, and Antonin Scalia figure prominently in the theory's development and promotion. They brought it to the foreground of modern discussions on the topic of executive power beginning in 2001, continuing throughout the Bush administration and beyond. The application of this legal doctrine has implications for the prosecution of the War on Terror, the subsequent 2003 U.S. invasion of Iraq, the use of enhanced interrogation techniques at sites such as Guantanamo Bay and Abu Ghraib, and mass surveillance. These are highlighted in the narrative. See also Autocracy Big Stick Policy Bush Doctrine Executive branch Federal Reserve Board Global policeman Imperial presidency The Imperial Presidency (book) Independent agencies of the United States government Parliamentary system Presidential system Signing statement State of exception War on terror References Further reading Essays by presidential scholars on the origins, history, use,