Some of the twelve Abu Ghraib prison guards found guilty of abuse will appeal on the grounds that they were wrongly convicted and used as scapegoats by the Bush Administration. The guards believe that the recent CIA memos show that Bush officials set them up and then sat back while they went on trial. Their lawyers will argue that the convicted guards could never have invented such torture techniques as stress positions or waterboarding on their own and that they were officially ordered to torture prisoners.
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