The Bush Six are six former officials of the United States government under the presidency of George W. Bush (2001–09) against whom criminal charges were filed in Spain in 2009 by Baltasar Garzón.After appeal of lower court ruling that proceedings could move forward, Spain's National Court dismissed the case for lack of jurisdiction. In closing the investigation, Judge applied reforms to the universal jurisdiction law introduced by the current Conservative government that imposed new limits on the jurisdiction of Spanish courts that require that cases involve suspects who are Spanish citizens or are living in Spain.