On November 9, 1994, the House used a section of the War Powers Resolution to state that U.S. forces should be withdrawn from Somalia by March 31, 1994; Congress had already taken this action in appropriations legislation. More recently, under President Clinton, war powers were at issue in former Yugoslavia, Bosnia, Kosovo, Iraq, and Haiti, and under President George W. Bush in responding to terrorist attacks against the U.S. after September 11, 2001. "[I]n 1999, President Clinton kept the bombing campaign in Kosovo going for more than two weeks after the 60-day deadline had passed. Even then, however, the Clinton legal team opined that its actions were consistent with the War Powers Resolution because Congress had approved a bill funding the operation, which they argued constituted implicit authorization. That theory was controversial because the War Powers Resolution specifically says that such funding does not constitute authorization." Clinton's actions in Kosovo were challenged by a member of Congress as a violation of the War Powers Resolution in the D.C. Circuit case "Campbell v. Clinton", but the court found the issue was a non-justiciable political question. It was also accepted that because Clinton had withdrawn from the region 12 days prior the 90-day required deadline, he had managed to comply with the act.