I may have been mistaken about this. Based on what the article says, it appears that Yaser Esam Hamdi was born in the U.S. and is therefore a U.S. citizen, but was captured in the Middle East.
In my mind, these are two completely different cases.
Although, it should be pointed out that the U.S. set a bad precedent by adjudicating Johnny bin Walker's case in a U.S. court instead of treating him as an enemy combatant.
Yup -- it's hard to justify holding Padilla without trial after we tried Lindh. Lindh should have been brought up before a military tribunal and shot. Or, he should have been tried for treason...and shot.