## Facts

- Mohammed Al-Adahi, a Yemeni national held at Guantánamo Bay, filed a habeas petition challenging his military detention as unlawful.
- The government asserted Al-Adahi was detainable as part of, or supporting, al-Qaeda or associated forces, relying on intelligence reports and other records concerning his travel, associations, and alleged connections to al-Qaeda figures.
- The district court granted habeas relief, concluding the government had not shown by a preponderance of the evidence that Al-Adahi was lawfully detainable.
- In reaching that result, the district court evaluated categories of the government’s proof largely one-by-one and discounted each item, finding none sufficient on its own.

## Issues

1. Whether the district court applied an improper approach to the government’s proof by treating evidence as requiring independent, standalone sufficiency rather than assessing the cumulative record.
2. Whether, under the preponderance-of-the-evidence standard applicable in Guantánamo habeas cases, the record supported continued detention.

## Decision

- The D.C. Circuit reversed the grant of habeas relief.
- The court held the district court erred by dissecting the government’s evidence into isolated pieces and rejecting each individually instead of weighing the evidence as a whole.
- The case was remanded for reconsideration under a holistic assessment of the full evidentiary record and proper application of the governing burden of proof.

## Legal Principles

- In habeas review of wartime detention, the government must justify detention by a preponderance of the evidence.
- Factfinding must assess the cumulative force of the evidence; circumstantial and interlocking proof may collectively satisfy the burden even if no single item is dispositive.
- A court commits legal error when it imposes an effectively heightened requirement that each piece of evidence independently establish detainability.

## Conclusion

The D.C. Circuit reversed habeas relief because the district court improperly evaluated the government’s evidence in isolation rather than considering its cumulative weight under the preponderance standard governing Guantánamo detention cases.


Mohammed Al-Adahi v. Obama, 613 F.3d 1102 (D.C. Cir. 2010)