Awlaki, an American-born cleric and al-Qaeda leader, was killed in September 2011. The 2010 memo provides legal justification for the United States to kill American citizens away from the battlefield without a trial.
Jameel Jaffer, an American Civil Liberties Union attorney who argued the case before the 2nd U.S. Circuit Court of Appeals, told the Associated Press that the memo's release "represents an overdue but nonetheless crucial step towards transparency. There are few questions more important than the question of when the government has the authority to kill its own citizens."