As word spread that an 8-year-old American girl was killed by a U.S. military operation in Yemen over the weekend, White House Press Secretary Sean Spicer made what sounded like a departure from Obama administration policy. Spicer, responding to a question about targeted killing attacks, assured reporters Tuesday that "no American citizen will ever be targeted." The Obama administration took a different approach, drafting a 2010 legal memo justifying the targeting of an American citizen for death by drone strike. The author of the memo, David Barron, was later appointed to be a federal judge.