This paper analyzes the legal arguments under-girding the Bush Office of Legal Council's (OLC) Torture Memo and the Obama OLC's Targeting Memo. Due to the Supreme Court's decision in Hamdi v. Rumsfeld, the previous emphasis on strong presidential powers gave way to an AUMF-based authorization of all fundamental and accepted incidents of war. While Obama's OLC did not use the so-called Commander-in-Chief override, it is in fact implied in the Targeting Memo's broad assertions of presidential authority based on the Supreme Court's capacious interpretation of the AUMF.