In this vote, the Senate voted 60 to 36 to confirm Alberto R. Gonzales to be Attorney General of the United States, the head of the United States Department of Justice and the nation's top law enforcement officer. Progressives opposed Gonzales's confirmation for several reasons, including his role in setting policies that may have contributed to the notorious abuse of prisoners by U.S. soldiers at Abu Ghraib in Iraq. Richard Durbin (D-IL) noted that Gonzales was "at the center of the debate over policies" that created a "climate" where these abuses could take place. Progressives raised the specific example of a memo that Gonzales, in his earlier position as White House Counsel, authored for President Bush stating that the Geneva Conventions concerning the treatment of prisoners of war did not apply to members of the Taliban or al Qaeda. (The Geneva Conventions are a longstanding international treaty guaranteeing the humane treatment of prisoners of war.) The Gonzales memo took the position that the "war against terrorism is a new kind of war," and that the Geneva Conventions were thus "render[ed] obsolete," and some of its provisions "quaint." In addition, several Progressives expressed the opinion that Gonzales had been less than forthcoming in answering questions on a number of issues that were posed by members of the Senate Committee on the Judiciary during his confirmation hearings. Republicans countered Progressives' arguments by stressing Gonzales's extensive credentials and qualifications, by noting that Gonzales had expressly stated his opposition to torture, and by accusing Progressives of turning Gonzales into a scapegoat for Administration policies that had since been disavowed. Gonzales was confirmed by a vote of 60 to 36 and thus became the Attorney General of the United States, head of the United States Department of Justice and the nation's top law enforcement officer.