Phil Carter, who sadly no longer maintains Intel Dump, called this back in October of 2004 in his Slate op-ed To Fight Another Day - subtitled the real reason Guantanamo detainees have returned to the battlefield.
New battlefield reports indicate that at least eight and as many as 25 of the 202 prisoners paroled by the Pentagon from Guantanamo Bay, Cuba, have rejoined the fight as members of the pro-Taliban resistance in Afghanistan, or as part of al-Qaida. One of the now-free prisoners fighting in Afghanistan proudly proclaimed that he won his parole simply by lying through his teeth throughout the time he was at Gitmo. And the Pentagon blames fibbing prisoners and inadequate screening systems - driven by this summer's Supreme Court terrorism decisions -for allowing these men to escape from captivity.
It's more than a little disingenuous to blame the Supreme Court for these problems, though, especially since most of these detainees were released before the June decisions were handed down. The real problem is that the Defense Department and U.S. intelligence community developed inadequate and unreliable systems for screening detainees at Guantanamo Bay. Just as one might expect, detainees exploited the flaws in this system to secure their freedom by any means available - including telling a few lies to deceive their captors into believing that they were innocent. Ironically, it didn't have to be this way - international law would have allowed the United States to warehouse the Gitmo detainees until "the cessation of active hostilities" and to interrogate them, too. But by rejecting the Geneva Conventions' restrictions on Gitmo detainee operations, the United States also rejected its benefits - creating the situation we have today in which paroled detainees have returned to fight against us...
More at Slate.