The convention of the South Dakota Republican Party voted in a 196-176 resolution to call for the impeachment of Obama based on his action to release five detainees from Guantanamo Bay in order to free Bowe Bergdahl from his Taliban captors.[29][30] Congressmember Allen West expressed the view that the prisoner exchange that brought the release of Bowe Bergdahl was grounds for impeachment.[31][21] John Dean, former White House Counsel to Richard Nixon, criticized the movement to impeach Obama as "insanity," arguing that Republican demands for impeachment are grounded in political disagreements rather than actual impeachable offenses. "Partisans promoting and pushing impeachment as a political solution to being out of power seem to forget that what comes around goes around. These people are not conservatives, who by definition seek to protect the system; rather they are radicals who are gaming our constitutional system," he wrote.[32]