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 Congress and no judicial precedent" immunized the contractors from tort liability, the Federal Tort Claims Act specifically excludes contractors, and tort liability would not interfere with government operations.