On September 18, 2001, the United States Congress adopted a joint resolution authorizing the President to use "all necessary and appropriate force against those nations, organizations, or persons he determines planned, authorized, committed, or aided" the terrorist attacks that killed nearly 3,000 people in New York City, Washington, D.C., and rural Pennsylvania a week earlier.' Acting pursuant to this authorization, United States military forces initiated combat operations in Afghanistan in October 2001. These operations were directed against both the al Qaeda terrorist network and Afghanistan's Taliban government, which, in the determination of the President, had supported al Qaeda.
Application of International Humanitarian Law by United States Courts, 28 Penn St. Int'l L. Rev. 177 (2009).