program. It is not clear whether a restricted notification procedure intended to protect sources and methods was expressly prohibited. Additionally, the sources and methods exception requires a factual determination as to whether it should apply to disclosure of the program itself or only to specific aspects. Peter J. Wallison, former White House Counsel to President Ronald Reagan stated, "It is true, of course, that a president's failure to report to Congress when he is required to do so by law is a serious matter, but in reality the reporting requirement was a technicality that a President could not be expected to know about." War Powers Resolution The majority of legal arguments supporting the program were based on the War Powers Resolution. The War Powers Resolution has been questioned since its creation, and its application to the NSA program was questioned. US citizens No declaration of war explicitly applied to US citizens. Under the War Powers Resolution the only option to include them was to enact an encompassing authorization of the use of military force. The AUMF did not explicitly do so. Under AUMF, "nations, organizations or persons" must be identified as having planned, authorized, committed, aided or harbored the (9/11) attackers. Military force is thereby limited to those parties. Since no US citizens were alleged to be involved in the 9/11 attacks, and since AUMF strictly states that war-time enemies are those who were involved in 9/11, including US citizens in general exceeds these provisions. Opinions that actions stemming from the Patriot Act are constitutional follow from the AUMF. Since AUMF wartime powers do not explicitly apply to US citizens in general, they are exempted from its provision as a function of Ninth Amendment unenumerated rights. Therefore, Patriot Act provisions that are unconstitutionally (violating the first, fourth and other amendments) applied to US citizens are not rescued by the AUMF. Other arguments Philip Heymann claimed Bush had misstated the In re: Sealed Case No. 02-001 ruling that supported Congressional regulation of surveillance. Heymann said, "The bottom line is, I know of no electronic surveillance for intelligence purposes since the Foreign Intelligence Surveillance Act was passed that was not done under the ... statute." Cole, Epstein, Heynmann, Beth Nolan, Curtis Bradley, Geoffrey Stone, Harold Koh, Kathleen Sullivan, Laurence Tribe, Martin Lederman, Ronald Dworkin, Walter Dellinger, William Sessions and William Van Alstyne wrote, "the Justice Department's defense of what it concedes was