Jay Bybee, as head of the Office of Legal Counsel, signed the August 1, 2002 torture memos largely drafted by his deputy John Yoo. These memos, produced at the request of Cheney office and White House Counsel Gonzales, authorized CIA use of waterboarding, cramped confinement, stress positions, and sleep deprivation. The OPR concluded the opinions constituted professional misconduct. Bybee was subsequently appointed to the Ninth Circuit Court of Appeals, effectively shielding him from professional consequences.