There is a culture of impunity that no one would be held fully accountable for detainee deaths.

Secretary Rumsfeld takes the extraordinary position in his brief that ordering torture was 'within the scope of his employment' as Secretary of Defense. Especially in light of recent finds that no one at senior levels has been held to account for gross acts of torture and abuse of detainees, this is a remarkable abdication of the responsibility of command.

We found across the board amazing flaws and failures in the way the investigations were conducted in case after case.

Death is a given in wartime. But this isn't about death in the heat of battle; this is about how we treat those already at the mercy of U.S. forces. It's about who is responsible for the policy and practice of the United States.

Our report finds that there is a gap between policies leadership says it respects on paper, and behavior it actually tolerates in practice. That's not a way to stop torture from occurring, and it's not a winning strategy in the fight against terror.

Looking closely at these cases, we found time and again badly flawed investigations, and a lack of command responsibility for what's gone wrong ? especially in cases where victims were tortured to death. The result across the board has been to create a culture of impunity, where no one, especially not command, is held fully accountable for detainee deaths. If the United States is serious about preventing torture going forward, there must be accountability up and down the chain of command.