Congress's role and responsibility of executive oversight and the scope and extent of presidential powers. CRS released a report on the NSA program, "Presidential Authority to Conduct Warrantless Electronic Surveillance to Gather Foreign Intelligence Information", on January 5, 2006 that concluded: On January 18, 2006 the Congressional Research Service released another report, "Statutory Procedures Under Which Congress Is To Be Informed of U.S. Intelligence Activities, Including Covert Actions". That report found that "[b]ased upon publicly reported descriptions of the program, the NSA surveillance program would appear to fall more closely under the definition of an intelligence collection program, rather than qualify as a covert action program as defined by statute", and, therefore, found no specific statutory basis for limiting briefings on the terrorist surveillance program. However, the report goes on to note in its concluding paragraph that limited disclosure is also permitted under the statute "in order to protect intelligence sources and methods". Legal action While not directly ruling on the legality of domestic surveillance, the Supreme Court can be seen as having come down on both sides of the Constitution/statute question, in somewhat analogous circumstances. In Hamdi v. Rumsfeld (2004) the government claimed that AUMF authorized the detention of U.S. citizens designated as an enemy combatant despite its lack of specific language to that effect and notwithstanding the provisions of (a) that forbids the government to detain an American citizen except by act of Congress. In that case, the Court ruled: However, in Hamdan v. Rumsfeld the Court rejected the government's argument that AUMF implicitly authorized the President to establish military commissions in violation of the Uniform Code of Military Justice. The Court held: In footnote 23, the Court rejected the notion that Congress is impotent to regulate the exercise of executive war powers: Dozens of civil suits against the government and telecommunications companies over the program were consolidated before the chief judge of the Northern District of California, Vaughn R. Walker. One of the cases was a class-action lawsuit against AT&T, focusing on allegations that the company had provided the NSA with its customers' phone and Internet communications for a data-mining operation. Plaintiffs in a second case were the al-Haramain Foundation and two of its lawyers. On August 17, 2006, Judge Anna Diggs Taylor of the United States District Court for the Eastern District of Michigan ruled in ACLU v. NSA that the Terrorist Surveillance Program was unconstitutional