Mark Kraft thinks so. At first glance, that’s how it looks to me, too, but I’d be interested to see what the General or his defenders have to say.
Unlike him, though, I don’t see any basis of inference that Rumsfeld did anything wrong. Of course, I don’t consider any of the things listed in that memo torture, or relevant to the more egregious acts at Abu Ghraib. I am concerned about the possible perjury before Congress, though. As they say, it’s not the act, it’s the cover up.