the State Department in April 2005. He continued to serve as a member of Rice's "inner circle". As Legal Adviser, Bellinger was the principal adviser on all domestic and international law matters to the Department of State, the Foreign Service, and the diplomatic and consular posts abroad. He was also the principal adviser on legal matters relating to the conduct of foreign relations to other agencies and, through the Secretary of State, to the President and the National Security Council. Bellinger was part of a group of Bush administration officials who advocated for minimum standards of treatment for detainees, protections for detainees prosecuted by military commissions, and the closure of the detention center at Guantanamo Bay. He helped persuade the White House to support the Detainee Treatment Act of 2005 (the McCain Amendment) and to close the secret CIA black sites in 2006. After the Supreme Court held in Hamdan v. Rumsfeld that Common Article 3 of the Geneva Conventions applied to the U.S. conflict with Al-Qaeda, Bellinger wrote a memo to the Department of Justice stating that the CIA interrogation program was not consistent with the Geneva Conventions. At the same time, Bellinger was also called upon to defend the Bush administration's counterterrorism policies to skeptical international audiences, serving as the administration's "chief flak catcher abroad". He gave numerous speeches and interviews explaining the U.S. legal approach to terrorism. Rice called Bellinger "indefatigable" in trying to address the concerns of U.S. allies. In 2006, Bellinger headed the U.S. delegation that negotiated the Third Additional Protocol to the Geneva Conventions that allowed the humanitarian aid societies of Israel and the Palestinian territories to join the International Red Cross/Red Crescent Federation. Bellinger has been credited with leading the Bush administration's shift in approach towards the International Criminal Court (ICC) in the administration's second term after President Bush agreed to the UN referral of the genocide in Darfur to the ICC in March 2005. In a series of speeches, Bellinger said the United States was prepared to assist the Court's investigation in Sudan even if it did not intend to join the Rome Statute. He has urged Congress to amend the American Servicemembers Protection Act to allow the United States to provide more support to the Court in certain war crimes investigations. In 2008, Bellinger represented the United States before the International Court of Justice (ICJ) in a case filed by Mexico