errors." In 2007, Garland dissented when the en banc D.C. Circuit reversed the conviction of a Washington, D.C. police officer who had accepted bribes in an FBI sting operation. Garland has taken a broad view of whistleblower protection laws, such as the False Claims Act (FCA), which creates a private cause of action against those defrauding the federal government. For example, in United States ex rel. Yesudian v. Howard University (1998), Garland wrote for the court in holding that a plaintiff alleging he had been fired by Howard University for whistleblowing could sue under the FCA for retaliation. In United States ex rel. Totten v. Bombardier Corp. (2004), Garland dissented when the court, in an opinion written by Judge John Roberts, held that the FCA did not apply to false claims submitted to Amtrak because Amtrak is not the government. Roberts justified his narrow reading by citing a book by Circuit Judge Henry Friendly. In dissent, Garland (who like Roberts had clerked for Friendly), cited Friendly's book as supporting the use of legislative intent, writing that Roberts was relying on "'canons' of statutory construction, which serve there as 'cannons' of statutory destruction." Garland's dissent, expressing concerns that the court's ruling would impede the government's ability to pursue false claims cases against federal grantees, is credited with sparking the Fraud Enforcement and Recovery Act of 2009, which eliminated the loophole. During confirmation hearings in 2005, Senator Chuck Grassley sharply questioned Roberts on why he had not adopted Garland's reading. Roberts replied, "Any time Judge Garland disagrees, you know you're in a difficult area." National security During Garland's tenure, the D.C. Circuit reviewed cases arising from the Guantanamo Bay detention camp. In al Odah v. United States (2003), a panel that included Garland unanimously held that federal courts could not hear challenges from Guantanamo detainees. In July 2011, Garland wrote for the unanimous panel when it rejected Guantanamo detainee Moath Hamza Ahmed al Alawi's petition for habeas corpus. In Parhat v. Gates (2008), Garland wrote for a panel that unanimously overturned the Combatant Status Review Tribunal's determination that a captured Uyghur was an enemy combatant. In Saleh v. Titan Corp. (2009), Garland dissented from the court's holding that former Iraqi detainees at Abu Ghraib prison could not sue private military contractors who participated in torture and prisoner abuse. Garland wrote that the suit should be allowed to proceed because "no act of