war. A U.S. court has rejected this argument, as it applies to detainees from al Qaeda. Henry T. King, Jr., a prosecutor for the Nuremberg Trials, has argued that the type of tribunals at Guantánamo Bay "violates the Nuremberg principles" and that they are against "the spirit of the Geneva Conventions of 1949." Some have argued in favor of a summary execution of all unlawful combatants, using Ex parte Quirin as the precedent, a case during World War II that upheld the use of military tribunals for eight German saboteurs caught on U.S. soil while wearing civilian clothes. The Germans were deemed to be unlawful combatants and thus not entitled to POW status. Six of the eight were executed as spies in the electric chair on the request of the U.S. President Franklin D. Roosevelt. The validity of this case, as basis for denying prisoners in the War on Terrorism protection by the Geneva Conventions, has been disputed. A report by the American Bar Association commenting on this case, states that the Quirin case "... does not stand for the proposition that detainees may be held incommunicado and denied access to counsel." The report notes that the Quirin defendants could seek review and were represented by counsel. A report published in April 2011 in the PLoS Medicine journal looked at the cases of nine individuals for evidence of torture and ill treatment and documentation by medical personnel at the base by reviewing medical records and relevant legal case files (client affidavits, attorney–client notes and summaries, and legal affidavits of medical experts). The findings in these nine cases from the base indicate that medical doctors and mental health personnel assigned to the DoD neglected and/or concealed medical evidence of intentional harm, and the detainees complained of "abusive interrogation methods that are consistent with torture as defined by the UN Convention Against Torture as well as the more restrictive US definition of torture that was operational at the time". The group Physicians for Human Rights has claimed that health professionals were active participants in the development and implementation of the interrogation sessions, and monitored prisoners to determine the effectiveness of the methods used, a possible violation of the Nuremberg Code, which bans human experimentation on prisoners. Lease agreement for Guantanamo The base, which is considered legally to be leased by the Cuban government to the American navy, is on territory that is