On June 9, 2002, two days before District Court Judge Michael Mukasey was to issue a ruling on the validity of continuing to hold Padilla under the material witness warrant, President George Bush issued an order to Secretary of Defense Donald Rumsfeld to detain Padilla as an "enemy combatant."
According to the text of the ensuing decision from the U.S. Court of Appeals for the Second Circuit, Padilla's detention as an "enemy combatant" (pursuant to the President's order) was based on the following reasons: .