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On Thursday, Judge Richard Leon of the U.S. District Court in D.C. issued a little-noticed decision granting dismissal in Al Janko v. Gates. The case is noteworthy, however, because Al Janko–unlike other former detainees who have filed civil suits–“is the first detainee who was released pursuant to a successful habeas petition to seek damages for acts he says occurred while in U.S. custody.” Al Janko’s now-dismissed suit asserted constitutional, statutory, and state tort law claims arising out of alleged mistreatment during his detention at Guantanamo against the United States, 20 civilian and military officials, and 100 John and Jane Does....

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