Author: Kevin Jon Heller

  • Call for Papers: German Yearbook of International Law

    by Kevin Jon Heller

    Our friends at the German Yearbook have asked us to post the following call for papers, and we are happy to oblige:

    The German Yearbook of International Law is Germany’s oldest yearbook in the field of public international law. The GYIL is published annually by the Walther Schücking Institute for International Law at the University of Kiel and contains contributions on topics addressing international law, including neighboring fields such as international criminal law, international humanitarian law, international economic law, and the international law of the sea. We aim to provide a forum for scholars in international law – both inside and outside Germany – to publish new research on and analysis of current issues in international law. The Yearbook features a ‘Forum’ for which a prominent scholar of international law is invited to write a stand-alone article and a ‘Focus’ section for which a group of experts are invited to write articles examining various aspects of a topic set in advance by the editors. Recent Focus sections have examined regional human rights mechanisms (2009), poverty as a challenge to international law (2008) and German approaches to international law (2007). The 2010 Focus section will examine climate change.

    In a departure from past editions, the “General Articles” section of Vol. 53 (2010) of the GYIL will be open to submissions from the entire academic community, which will be independently peer-reviewed by a community of renowned experts. All work submitted will be scrutinized based on its intellectual quality and its significance in advancing academic discourse. The Editors have thus decided to issue this general call for papers to invite interested parties to submit a paper for consideration for inclusion in the forthcoming edition.

    Persons interested in publishing in the GYIL should submit a manuscript conforming with the house-style of the GYIL (which is available on request) dealing with any topic of interest in the field of public international law to the editors by 1 September 2010. Potential authors are also requested to include a brief biographical statement, including information regarding current academic affiliations and general research interests. All inquiries and materials should be addressed to the assistant editors of the GYIL via e-mail: [email protected]

  • Tim McCormack Appointed ICC Advisor

    by Kevin Jon Heller

    I am delighted to announce that Luis Moreno-Ocampo has appointed my friend and colleague Tim McCormack to be the Office of the Prosecutor’s Special Adviser on International Humanitarian Law.  From the announcement:

    Professor McCormack, from the Melbourne Law School at the University of Melbourne will help the Office of the Prosecutor to develop a solid understanding of complex legal issues such as indiscriminate attack, proportionality and command responsibility. He will also provide advice on the application and interpretation of international humanitarian law in relation to crimes within the jurisdiction of the Court, as well as on general principles of criminal law and legal issues related to military structures.

    Tim is, to say the least, eminently qualified for the position.  From his bio:

    Tim has developed an international reputation for his scholarship in International Humanitarian Law and in International Criminal Law. From 2002–2006 he acted as amicus curiae on international law matters to the judges of Trial Chamber III of the International Criminal Tribunal for the Former Yugoslavia in The Hague for the trial of Slobodan Miloševic. From 2003–2007 he provided expert International Humanitarian Law advice to Major Mori for the defence of David Hicks. In that capacity Tim travelled to Guántanamo Bay to attend the US Military Commission proceedings against David Hicks in March 2007.

    Tim has established one of the world’s strongest concentrations of research higher degree work in International Humanitarian Law, currently supervising 10 doctoral students. He is the general editor (with Christopher Greenwood of the London School of Economics) of the world’s first academic book series dedicated to International Humanitarian Law (with Martinus Nijhoff Publishers in Leiden) and has recently co-edited the twentieth volume of the series (his sixth book), The Legacy of Nuremberg: Civilising Influence or Institutionalised Vengeance? Tim is editor-in-chief of the prestigious Yearbook on International Humanitarian Law (published by the Asser Press in The Hague), and is also a member of the editorial board of several other leading international academic journals.

    I know that Tim will prove to be a valuable resource for the OTP.  My congratulations to him!

  • “Future Perspectives on International Criminal Justice” Published

    by Kevin Jon Heller

    The wide-ranging book, which is edited by Carsten Stahn and Larissa van den Herik and published by Cambridge/TMC Asser, is well worth checking out.  Here is the table of contents:

    Part I. The Influence of Scholars and Practitioners on the Development and Conceptualization of International Criminal Law: 1. ‘Satires of circumstance’: some notes on war crimes trials and irony Gerry Simpson; 2. The banality of evil on trial Alette Smeulers and Wouter Werner; 3. Why international criminal lawyers should read Mirjan Damaška Harmen van der Wilt; 4. The gentle humanizer of humanitarian law – Antonio Cassese and the creation of the customary law of non-international armed conflict Tamás Hoffmann; 5. The international criminal legal process: towards a realistic model of international criminal law in action Christoph Burchard.

    Part II. Theorizing International Criminal Justice: 6. The two liberalisms of international criminal law Darryl Robinson; 7. International criminal law at the crossroads: from ad hoc imposition to a treaty-based universal system Kai Ambos; 8. In search of the ‘vertical’: towards an institutional theory of international criminal justice’s core Frédéric Mégret.

    Part III. Re-Assessing the Balance Between International and Domestic Jurisdiction: 9. Situational gravity under the Rome Statute Kevin Jon Heller; 10. When law ‘expresses’ more than it cares to admit: comments on Heller Mark Osiel; 11. Should the prosecution of ordinary crimes in domestic jurisdictions satisfy the complementarity principle? Dawn Sedman; 12. Interpreting complementarity and interests of justice in the presence of restorative-based alternative forms of justice Marta Valiñas; 13. Universal jurisdiction and the prosecution of excluded asylum seekers Elizabeth Santalla.

    Part IV. De-Individualizing International Criminal Law: Can Abstract Entities Commit International Crimes After All?: 14. The Inter-American Court of Human Rights and the aggravated state responsibility operationalizing the concept of state crime Scott Doucet; 15. Corporations as future subjects of the International Criminal Court: an exploration of the counterarguments and consequences Larissa van den Herik; 16. Gray war zone? The question of contractual control of the privatization of warfare and the civilianization of the military Dan Kuwali; 17. Holding private military companies accountable for their crimes: the applicability of the commander/superior responsibility doctrine Materneau Crispin.

    Part V. Crime Definitions Revisited: 17. Defining the crime of aggression Astrid Reisinger; 18. Complementarity and aggression: a ticking time bomb? Nicolaos Strapatsas; 19. The recruitment and use of child soldiers: some reflections on the prosecution of a new war crime Michael E. Kurth.

    Part VI. System Criminality and the Principle of Personal Fault: A Balancing Test in Setting the Appropriate Standards for Modes of Liability: 21. The difficulty with individual criminal responsibility in international criminal law Gideon Boas; 22. Current trends on modes of liability for genocide, crimes against humanity and war crimes Héctor Olásolo; 23. From ‘conspiracy’ to ‘joint criminal enterprise’: in search of the organizational parameter Athanasios Chouliaras.

    Part VII. Towards One International Criminal Procedure?: 24. Trends in the development of a unified law of international criminal procedure Göran Sluiter; 25. Witness memory and the manufacture of evidence at the international criminal tribunals Alexander Zahar; 26. Remedies for war victims Liesbeth Zegveld; 27. Victim participation in ICC proceedings Nino Tsereteli; 28. Arrest and surrender under the ICC Statute: a contextual reading Carsten Stahn.

    As you will see, the book includes my essay on situational gravity and a response by Mark Osiel.  I was honored to find out that Mark wanted to respond to my essay, and I recommend his contribution highly.

  • Karadzic “Regularly” Boycotts Trial

    by Kevin Jon Heller

    At least according to Dominic Hughes, a BBC reporter who obviously can’t be bothered to know what he’s talking about:

    Perhaps not surprisingly Radovan Karadzic has been a reluctant participant in this trial.

    The former leader of the Bosnian Serbs has appeared just a few times, regularly boycotting the process.

    Apparently, “once” now qualifies as “regularly.”  Good job, BBC!

    ADDENDUM: Hughes also claims that “[p]rosecutors have recently narrowed down the range of charges and specific instances in an effort to speed up the process.”  In the real world, of course, the prosecutors refused to narrow the charges, limiting themselves to reducing the number of municipalities at issue in the trial.  Apparently Hughes can’t be bothered to read, either.

  • Two Mistaken Defenses of Torture

    by Kevin Jon Heller

    Both Humblelawstudent and Stuart Taylor have criticized my previous post.  Both misunderstand the federal torture statute and the concept of torture in important — and unfortunately all too common — ways, so it is worth explaining their errors in a separate post.

    Let’s begin with HLS.  He claims that, contrary to my assertion, “the statute requires the interrogator to actually cause “severe mental pain or suffering,” because “’[t]hreatening’ is only torture where the threat of the ‘infliction of several physical pain or suffering’ causes “severe mental pain or suffering.”  That is incorrect, although the poor drafting of the statute makes it an easy mistake to make.  Again, here is the text of the statute:

    (1) “torture” means an act committed by a person acting under the color of law specifically intended to inflict severe physical or mental pain or suffering (other than pain or suffering incidental to lawful sanctions) upon another person within his custody or physical control;

    (2) “severe mental pain or suffering” means the prolonged mental harm caused by or resulting from—

    (A) the intentional infliction or threatened infliction of severe physical pain or suffering;
    (C) the threat of imminent death.

    The elements of torture are contained in the first paragraph of s. 2340.  As defined, the actus reus of the crime consists of three elements: (1) an “act”; (2) the commission of that act by a “person acting under color of law”; and (3) the commission of that act “upon another person within his custody or control.”  (1) is a conduct element; (2) and (3) are circumstance elements.  The mens rea of the crime is then the commission of the act with the specific intent to inflict “severe physical or mental pain or suffering.”

    Notice what is missing from the crime: a consequence element.  Nothing in paragraph one requires the act to actually cause “severe physical or mental pain or suffering”; to be guilty of torture, the interrogator must simply specifically intend to cause it.  If he specifically intends to cause “severe physical or mental pain or suffering” but fails, he has still committed the crime.

    To be sure, it is easy to misunderstand the crime as HLS does, assuming that the second paragraph of s. 2340 means that torture requires the act to cause a particular consequence.  The statute is not well drafted.  But paragraph two simply defines what it is that the interrogator must specifically intend to do — he must specifically intend his act to cause “severe mental pain or suffering,” which is defined as “prolonged mental harm.”  In other words, to be guilty of torture, the interrogator must specifically intend to cause “prolonged mental harm”; whether he actually causes such harm is irrelevant.

    And how does he do that?  How does an interrogator specifically intend to cause “prolonged mental harm”?  That question is answered by the first quoted subparagraphs of paragraph two: an interrogator specifically intends to cause “prolonged mental harm” if he actually inflicts “severe physical pain or suffering” capable of causing such mental harm, or if he threatens to inflict “severe physical pain or suffering” capable of causing such mental harm.  Differently put, the interrogator cannot be said to have specifically intended to cause “severe physical or mental pain or suffering” if his actual violence or his threats of violence are not capable of producing “prolonged mental harm.”  Whether he actually produces such harm is irrelevant.

    Again, HLS’s fundamental mistake is to assume that the federal torture statute contains a consequence element.  It doesn’t, as the above analysis indicates.  Need more proof?  Consider the Convention Against Torture and the Rome Statute.  Here are their definitions of the crime:

    CAT, art. 1(1): For the purposes of this Convention, the term “torture” means any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession.

    Rome Statute, art. 7(2)(e): “Torture” means the intentional infliction of severe pain or suffering, whether physical or mental, upon a person in the custody or under the control of the accused; except that torture shall not include pain or suffering arising only from, inherent in or incidental to, lawful sanctions.

    Notice the difference?  Both CAT and the Rome Statute define torture as a crime of consequence: the intentional conduct must actually cause severe pain or suffering; it is not enough for the interrogator to specifically intend to cause it.  The federal torture statute, by contrast, only requires the specific intent.

    Now, onto Taylor.  Taylor’s criticism, once you cut through the bombast, is more serious, though still mistaken.  Here is what he wrote:

    In addition, it is fatuous for Heller to claim that interrogators who threaten to cause (or who do cause) cause short-term “severe mental pain or suffering” in the colloquial sense must therefore “specifically intend” to cause (or even to threaten) severe mental pain in the statutory sense, which requires proof of “prolonged mental harm.” The same is true even if one assumes that the interrogator intends to threaten severe physical pain. Yes, such a threat is intended to cause severe mental pain in the colloquial, short-term sense. But it clearly would not be specifically intended to cause prolonged mental harm — not unless the interrogator’s only motivation is sadism, which no honest person has claimed.

    First, like HLS, Taylor does not understand that torture does not require proof that “prolonged mental harm” actually resulted from the waterboarding; again, the crime only requires proof that the interrogator specifically intended to cause such prolonged harm.  But Taylor’s mistake does not actually affect the core of his argument, which is that, when we delve into the minds of the waterboarders, we find only the subjective intent to cause short-term mental harm.  Differently put, Taylor believes that the interrogator specifically intends to cause severe mental harm — the threat of death — only for the duration of the waterboarding; once the waterboarding ends, the specific intent to cause severe mental harm ends.

    That is not a ludicrous position, but it is incorrect.  If we assume that that the CIA interrogators honestly believed that one act of waterboarding would normally be enough to convince a detainee to speak, Taylor would have an argument — in such a situation, the interrogators would not have needed to intend to cause “prolonged” mental harm, because the specific intent to cause transitory mental harm (lasting the duration of the waterboarding) would have been enough.  But that assumption is clearly false, given how often the CIA interrogators waterboarded the detainees.  Waterboarding a detainee 183 times (or even just multiple times) is a clear indication that the interrogators were fully aware that only a series of waterboardings would suffice to terrify a detainee into talking.  The detainee — particularly a hardened, well-trained terrorist — might not fear death in the first waterboarding.  Perhaps not even in the first few.  But enough waterboardings?  Eventually the detainee would realize that his interrogators might kill him if he didn’t eventually talk.

    The point of the CIA’s waterboarding, then, was precisely to create prolonged mental harm in the mind of the detainee.  The interrogator wanted the detainee to fear death from the first waterboarding until the final waterboarding (however many that was) that convinced him to talk.  And more than that: the interrogator wanted the detainee’s fear of death to escalate with each waterboarding, because that escalation was the key to breaking down his resistance.

    This is a much more convincing explanation of the purpose of waterboarding than Taylor’s.  Taylor would have us believe that each of the 183 waterboardings to which Khalid Sheikh Mohammed was subjected were completely independent of each other — that although the interrogators wanted to make KSM fear death during each waterboarding, they had no desire to make him fear death between waterboardings.  But that is absurd: if the CIA interrogators did not want the fear of death to carry over between waterboardings, it made no sense for them to waterboard him 183 times.  If KSM could resist talking despite the fear of death once, and if his fear of death did not grow over time, why would they continue to waterboard him?  Wouldn’t they have simply said, “bummer, he’s too tough to be convinced to talk by the short-term threat of death.  We will have to stop waterboarding him, because we are not trying to cause him to suffer prolonged mental harm by making him increasingly afraid that we will kill him if he doesn’t talk”?

    They didn’t say that, of course, and they didn’t stop waterboarding him.  And the reason is clear: because they were not specifically intending to cause KSM only short-term mental harm.  They were specifically intending to cause him prolonged mental harm — harm that lasted long enough, and escalated far enough, to convince him to talk.  And that is his waterboarding, and all the other waterboardings like it, were torture.

    A final point: although this process of creating an escalating fear of death through multiple waterboardings is sadistic, no one is claiming — Taylor’s strawman aside — that the interrogators are motivated by sadism.  They are motivated by the desire to convince the detainee to talk, which they accomplish by using multiple acts of waterboard to heighten the detainee’s fear of death.

  • Stuart Taylor’s Apologia for Torture

    by Kevin Jon Heller

    David Luban and Stuart Taylor are having an interesting exchange at Balkinization over whether the CIA’s use of waterboarding qualifies as torture under the federal torture statute, 18 USC 2340.  Luban accuses Taylor of embracing “the fundamental trick used by the torture lawyers: pretending that the legal definition of ‘torture’ is something technical rather than ‘colloquial’,” when in fact there is no meaningful difference between the two concerning torture’s requirement that the interrogator intentionally inflict “severe physical or mental pain or suffering.”  Taylor then accuses Luban of “grossly” misleading Balkinization’s readers about his argument, defending his claim that CIA waterboarding does not qualify as torture as follows (my emphasis):

    The statute specifically sub-defines “severe mental pain” as occurring (for purposes of the statute) only if there is (among other things) “prolonged mental harm.”

    Even OPR implicitly conceded that “prolonged mental harm” must mean more than a few minutes or hours of severe mental pain when it gave up on challenging the Bybee-Yoo interpretation of that phrase after Attorney General Mukasey’s response had shown OPR’s draft criticism to be an embarrassment to OPR.

    And the statute’s specific intent requirement — which Luban conveniently ignores — makes it utterly clear that an interrogator who in good faith believes that neither prolonged mental harm nor severe physical pain would result from his actions cannot have violated the torture statute.

    As Margolis found, 10,000-plus SERE trainees have almost unanimously reported that waterboarding caused no severe physical pain and no prolonged mental harm. This is dispositive as to “physical” and — together with the specific intent requirement — almost dispositive as to “prolonged,” given the assumptions that the CIA gave Bybee and Yoo about how waterboarding would be done and would be limited.

    This sounds convincing — until one realizes that Taylor has conveniently ignored part of the torture statute:

    (1) “torture” means an act committed by a person acting under the color of law specifically intended to inflict severe physical or mental pain or suffering (other than pain or suffering incidental to lawful sanctions) upon another person within his custody or physical control;

    (2) “severe mental pain or suffering” means the prolonged mental harm caused by or resulting from—

    (A) the intentional infliction or threatened infliction of severe physical pain or suffering;
    (C) the threat of imminent death

    As sec. 2340(2)(A) makes inordinately clear, an interrogator does not have to actually cause “severe mental pain or suffering” to be guilty of torture; he is equally guilty if he merely threatens to cause “severe mental pain or suffering” or “imminent death.”  That is a critical distinction, because it indicates why Taylor’s reliance on SERE waterboarding is anything but “dispositive”: even if we accept that SERE waterboarding and real waterboarding actually inflict the same amount of physical pain, they clearly do not threaten to inflict the same amount of physical pain.  SERE trainees know full well that they are not going to be waterboarded to death.  Detainees have no such guarantee, which is what makes waterboarding so terrifying.

    And, of course, creating such terror is the entire point — the “specific intent” — of actual waterboarding.  There is a reason that interrogators want to make the detainee fear that he will be drowned if he does not cooperate: it is that fear that is supposed to convince the detainee to talk.  For waterboarding not to be torture, therefore, we have to assume that interrogators believe that detainees will talk even if they don’t fear being seriously injured or killed by the waterboarding.  But that is absurd: people like Taylor want to use waterboarding precisely because they believe lesser forms of interrogation are not “convincing” enough to crack hardened and highly-trained terrorists.

    Taylor has no convincing objection to this analysis — which is no doubt why his response to Luban simply ignores the “threat” prong of the federal torture statute.  His only possible response is that the mental harm caused by real waterboarding’s inherent threat of death does not qualify as “prolonged.”  Once again, though, it is easy to see that the SERE analogy is inapposite: SERE waterboarding does not cause “prolonged mental harm” because the trainees know that, no matter how often they are waterboarded, they will not be killed.  A detainee, by contrast, necessarily suffers “prolonged mental harm” because, having been intentionally made to fear for his life once, he has no guarantee that he will not be waterboarded again — this time to death.  It thus makes no difference whether the detainee is only waterboarded once or, like Khalid Sheikh Mohammed, 183 times.  From the very first moment he is waterboarded, he suffers ongoing — prolonged — mental harm.

    Taylor closes his reply to Luban by claiming “thus does Luban descend from weak, to weaker, to weakest, while consistently misleading readers throughout.”  That’s an ironic claim, given Taylor’s selective discussion of the federal torture statute.

  • Osiel on “Rethinking the Law of War Crimes”

    by Kevin Jon Heller

    The following is a guest-post — actually a short book-proposal — by my friend Mark Osiel, the Aliber Family Chair in Law at the University of Iowa.  I have agreed to post it despite the inordinate jealousy I feel toward his remarkable productivity.  Mark would greatly appreciate comments and criticisms, especially examples and counter-examples of what he is trying to get at.

    Rethinking the Law of War Crimes: “Collateral Damage”and “Distinction”

    Current law on war crimes is deeply disappointing to most people – public and legal professional — who pay it any attention, notwithstanding many prosecutions for mass atrocity by new international courts in recent years. Observers on both the Right and Left agree that the law’s expectations in this area depart radically from those of morality, that is, from any defensible conception of what a truly “just war” would look like, how it would be fought. Most concur that the relevant rules are far too generous to fighters at some points, too demanding of them at others; too weak in protecting innocent civilians, too indulgent of violence by other civilians. Wide agreement also exists that obvious aggressors would, in a genuinely just law of war, enjoy less legal protection than their aggrieved victims. The law will have nothing of this.

    Those on the Left, especially, insist that a just law of war crimes would preclude the cynical invocation of “collateral damage” to excuse the eminently foreseeable killing of many innocents that has occurred in several recent confrontations. Many on the Right, particularly, proceed to denounce the habitual exploitation of civilian status and its protections by those organizing large-scale terror attacks on population centers while deploying their own civilians to “shield” military installations from counter-attack. Both ends of the political spectrum, as well as many people in between, concur that the disjuncture between law and justice has grown so great that longstanding international rules of war no longer merit respect or adherence. It is no exaggeration to describe the current situation as something of a crisis, one that – given its moral magnitude — should concern any conscientious citizen of the world.

    How did the respective demands of law and morality in war apparently come to deviate so profoundly? Might anything be done to realign them?

    The conventional account of law’s failings accusingly points to the world’s military powers who, immersed in the anarchy of global politics, find it necessary to make hard-hearted calculations of national self-interest in ways that severely limit the moral ambit and aspirations of international law. Some find this situation acceptable; most consider it deplorable. They nonetheless agree on the causal story and its implications for likely legal progress.

    There is a different type of obstacle, however, no less weighty if rarely noticed. Attending to it may even help us reassess the apparent constraints of realpolitik itself, by identifying weaknesses in the law better attributable to other factors. The central problem is that, despite millennia of human experience with war and significant advances in its genuinely scientific aspects, those who professionally make (and study) it have few clear answers to several of its perennial puzzles and little ability accurately to predict its ever-shifting contours. In light of these cognitive shortfalls, as we may call them, it should come as little surprise that we have learned so little about how best to govern war, and in particular, about where exactly to draw the line – amidst the ubiquitous violence that is intrinsic to war — between its lawful and criminal features. We must rethink important features of war crimes law from this more skeptical, Socratic vantage point.

    The most insistent questions therefore become, at the level of particular legal doctrines: What does the law of war crimes assume about how much of what kind of information, technical and ethical, fighters at all levels know or can be expected to acquire? When, and on what empirical basis, are these assumptions warranted? Finally, can law’s frequent departures from the apparent requirements of justice – as seen through the abstract lens of ideal-theory — be better ascribed to cognitive shortfalls than to constraints of realpolitik? These questions lead us to pose a host of still more specific queries, virtually never raised by legal scholars of war crime.

    Consider quickly a few of these. The law requires commanders to employ no more force than “necessary” to achieve a given military aim. But how much do they really know about the measure of force required to achieve a given tactical goal before undertaking it? Might the limits of their understanding here explain the relative lenience of courts when judging them?

    The law further demands that “incidental” harm to civilian life and property not become excessive “in relation to the concrete and direct overall military advantage anticipated.” On what kinds of learning do soldiers rely when weighing the competing values in balance here? To say that these values – innocent life versus military success — are incommensurable (as philosophers often do) is simply a more technical way of saying that we know of no acceptable means for measuring them along a single scale?

    For that matter, when commanders try to anticipate likely military advantage from a tactical exercise of force, what must they know about how their contemplated action contributes to larger operational and strategic goals? If the law expects very much here, it almost immediately exceeds the limits of what soldiers know. If it demands very little, requiring awareness only of immediate effects, then it ignores how an exercise of force “disproportionate” at the tactical level can sometimes greatly advance the prospects of operational and even strategic victory. This is illustrated as in the sinking of the Belgrano by Britain during the Falklands/Malvinas War. The ship posed no tactical threat at the time and place, but its destruction contributed greatly to Argentina’s decision to abandon the Islands.

    Conversely, a tactically “proportionate” use of force sometimes turns out to have highly prejudicial consequences for strategic goals, as when vivid images of a small number of innocent civilian deaths from a successful drone strike on a major terrorist are broadcast across the globe on Al Jazeera. If international legitimacy for nation-building efforts is the central strategic aim, then legal assessments of proportionality in the use of force become inseparable from the public’s moral assessment of whether excessive harm has been caused, however unintentionally, as Dale Stephens observes. Because public opinion blows ephemerally in the wind, no workable legal test of proportionality – and surely none of international criminal law – could be built on this basis. In sum, what is proportionate at one level of military decision-making is often disproportional at another, in ways that elude the law’s convincing conceptual grasp. This contributes to the danger of criminalizing what are simply reasonable disagreements – professional and more political — over the necessary measure of force in a given circumstance.

    Once thinking in this epistemic sort of way, we find other such puzzles immediately suggesting themselves. “Effects-based” targeting has become popular among U.S. Air Force strategists, though it entails intentional targeting of civilians, i.e., civilian leaders – in both government and business – upon whose support the criminal policies of a repressive state, such as Serbia’s toward Kosovo in 1999, critically depend. From a moral point of view, effecting policy change in this way would clearly be preferable to targeting thousands of reluctant Serbian conscripts. The advocates of effects-based targeting are right in thinking that we often have information permitting more fine-grained distinctions of threat and culpability for aggression and war crime than those entailed in a bright-line distinction of status between combatant and civilian.

    But actual experience with effects-based targeting is discouraging about our capacity to predict the true consequences, intended and unintended, of such civilian targeting. If our powers of social analysis were more advanced, if they strongly suggested which civilian elites to target in order to produce what changes of criminal policy, we would all surely support the legal revisions necessary to permit this. Despite the bluster of its defenders, however, we simply lack the learning to render this theory workable.

    Another illustration: When the strategic decision-makers of Western powers contemplate assassinating a leading terrorist, to what extent do they think, know, and worry about how this may implicitly advance such a practice as an incipient customary right and thereby expose their own successors and allies to greater risk of similar attack in turn? If they were certain of their de facto power to prevent such rejoinder, they would have little hesitation about advancing such a de jure norm, in the knowledge it would not come back to haunt them in practice. They do not do so. How much does their inescapable ignorance of such long-range repercussions restrain them from officially acknowledging the fact of these attacks and defending their legality (as some at Opinio Juris urge they should), attacks greatly increased under the Obama administration?

    Finally, many non-lawyers today demand that jus in bello restrictions on acceptable means of fighting no longer remain entirely indifferent to jus ad bellum rules on resort to force. Such people – both ordinary citizens and moral thinkers – increasingly believe that a lesser measure of incidental civilian loss is appropriate when grave doubts arise about the underlying cause such force claims to advance. In other words, when evaluating a particular lethal action in war, most people refuse to isolate this question from their broader assessment of the actor’s initial resort to, and continuing employment of force in the first instance. They simply repudiate the law’s historic insistence on such a separation — and hence too reject the idea that proportionality must have distinct meaning in these disparate contexts, as the law continues to insist.

    Yet to what extent can soldiers beneath the highest echelons can be expected to recognize whether the war aims for which they fight are just, or consistent with the United Nations Charter? What does the evidence suggest about their propensity to reach conclusions on such matters independently of their superiors’ explanations and exhortations? When reasonable people throughout the world disagree profoundly over the justice of given war aims, it is a perilous for international law to enshrine some contested answer to the question, making it the basis of criminal liability.

    There is some recognition of this problem in how the U.N. Charter severely curtails the broader, theological rationales for just resort to force, focusing almost exclusively on national self-defense against armed attack, with the latter term defined quite narrowly. There is further such recognition in the recent efforts to define the crime of “aggression” so that only top policymakers may be held liable for it. They are in the best position to know both the pertinent strategic facts and their own, true rationales for a policy of war.

    My working hypothesis is that such inquiries will suggest that the central obstacle to a better law of war crimes lies less in the tough imperatives of geopolitics, as “realists” are wont to insist, than in these cognitive considerations, more subtle and conceptually elusive. For lack of a better word (and at some risk of portentousness), we might call these considerations “epistemic.” To suggest that this is where we should direct our inquiries, however, is not to imply that such challenges necessarily prove any more tractable than the better-known and more brutal ones of realpolitik.

    The upshot of such an analysis will be to refute criticism of war crimes law from the Right, to the effect that such is too demanding (with respect to distinction) and critique from the Left (with regard to proportionality) that it is not demanding enough. In other words, the law of war crimes can do more good work than the Right generally allows, but less than the Left invariably demands. The legal status quo in this area, however disappointing from the perspective of any ideal theory of justice, is pretty much the best we can expect for a long time.

    All suggestions welcome on how to develop (and qualify) this argument!

  • At Least One British Prime Minister Faces ICC Charges…

    by Kevin Jon Heller

    Sure, it’s in Roman Polanski’s new film, The Ghost Writer.  But it’s still cool — especially when the Prime Minister, played by an excellent Pierce Brosnan, is charged with war crimes and crimes against humanity for aiding and abetting torture by the United States!

    I have to admit, I never thought I’d live to see Article 25(3)(c) of the Rome Statute — the aiding and abetting provision — read word-for-word in a film.  And that’s not all: not only does the film properly invokes Article 7 and Article 8 as covering crimes against humanity and war crimes respectively, the scenario it depicts could actually result in an ICC prosecution.

    That said, the film does make two errors — one blatant, one subtle.  The blatant error is that it refers to the “Special Prosecutor” of the ICC.  The subtle error (minor spoiler alert!) is that it implies that an unwilling witness could be required to testify, when the ICC lacks subpoena power.

    On the bright side, the “Special Prosecutor” in the film is a woman.  We all know that would be an improvement over the current one…

  • The President Takes a Ruler to the Registry — Again

    by Kevin Jon Heller

    I am sitting in the Indianapolis airport as I write this, heading home from a conference on the Milosevic trial.  The conference was easily the most enjoyable I’ve ever attended — I vastly prefer small, specialized conferences to mega-events like the AALS or ASIL.  The attendees were a superb mix of academics, former OTP investigators and analysts, and defence attorneys.  I enjoyed their company immensely.

    Not surprisingly, I was asked dozens of questions about Dr. Karadzic’s trial.  I couldn’t answer most of them, for obvious reasons, but I can happily report that the President of the ICTY has reversed yet another attempt by the Registry to punish Dr. Karadzic for exercising his right of self-representation, this time concerning funding.  The Registry has consistently sought to undermine Dr. Karadzic’s defense by relying on absurd interpretations of its Remuneration Scheme.  Most recently, it has insisted (1) that the defence team is entitled to only 250 hours of paid legal assistance per month during the adjournment phase (which will end on March 1), despite the fact that the Prosecution has disclosed another 300,000 documents since the beginning of the adjournment; (2) that the defence team is entitled to only 150 hours of paid legal assistance per month during trial, even though that would force Dr. Karadzic to dismiss seven of the eight members of his defence team before trial, leaving him with only one legal associate and no investigators or case managers; and (3) that Peter Robinson would continue to be paid 25 euros per hour, despite the fact that he will have more responsibility once trial begins, because the Trial Chamber has granted him the right to make legal submissions during trial.

    To our great relief, the President reversed all three of those funding decisions.  The Registry attempted to defend the adjournment-phase remuneration on the ground that all of the pre-trial work, such as reviewing discovery, should have been concluded before trial began last year — conveniently overlooking the 300,000 documents the Prosecution disclosed after that date.  The President rejected that argument, concluding that “no reasonable person considering these factors could have arrived at the decision that an allocation of 250 hours for the entire defence team per month during the adjournment phase was sufficient in the given circumstances” (para. 39; emphasis mine).

    The President was equally dismissive of the Registry’s position on trial-phase funding.  “I do not consider that a reasonable person having properly taken into account the complexity of Karadzic’s case could have arrived at the decision that providing remuneration for one full-time support staff member to assist Karadzic out-of-court is sufficient to enable Karadzic to effectively represent himself during trial, and that departure from the Remuneration Scheme is not warranted.  Rather, in rendering his decision, I am convinced that the Registrar erred” (para. 43).  He thus granted the defense 750 hours of paid legal assistance per month during the trial, enough to allow Dr. Karadzic to have a five-person defence team — the number that a represented defendant is entitled to during trial.

    Finally, the President rejected the Registry’s position on Peter’s remuneration, concluding that the Registry’s failure to take into account the Trial Chamber’s desire to have Peter address it on legal issues “was unreasonable and in contravention of the requirement that legal associates must be adequately compensated” (para. 52).  He thus determined that Peter was entitled to 71 euros per hour during the trial — nearly a 300% raise!

    You would think that the Registry would feel some shame that the President keeps reversing its decisions on the ground that “no reasonable person” could have agreed with them.  Alas, this Registry — which sees itself as an extension of the Prosecution, despite the fact that it is supposed to be independent — is obviously incapable of feeling shame.  Its motto is simply “convict at all costs.”

    Wait, check that.  The Registry’s motto is actually “convict at no cost.”  Kudos to the President for not letting them get away with it.

  • David Margolis’s Whitewashing

    by Kevin Jon Heller

    I don’t have much time, but it’s important to note that although David Margolis may be a career attorney, he has made a career out of preventing government officials from being held accountable for their misconduct.  From Scott Horton:

    But “Yoda” Margolis also knows the “dark side” of political intrigue. He was long the man to whom political appointees could turn for protection and guidance when the going got rough, in both Democratic and Republican administrations. For instance, Bloomberg reported that both Kyle Sampson and Monica Goodling turned instinctively to Margolis for protection and support when the U.S. attorney’s scandal erupted.

    What this means in practice can be seen in dozens of cases involving seriously unethical conduct by political appointees. Margolis has a one-size-fits-all solution for these cases: sweep them under the carpet.

    In “Prosecutorial Ethics Lite,” I reviewed what Margolis did when confronted with a case in which a U.S. attorney used all the powers she could assemble to destroy an insurance executive who had commenced a law suit against her husband. Ethics rules clearly required her recusal. But in the face of a compelling mass of evidence, Margolis concluded that everything was just fine. He allowed the U.S. attorney to pass nominal control of the matter to the head of her criminal division. The abuse of office pressed forward, with Margolis’s blessing.

    Justice Department insiders also note that Margolis single-handedly blocked efforts to secure a meaningful review of the prosecution of former Alabama Governor Don E. Siegelman, after more than 90 attorneys general from around the country advised the Justice Department of a series of gross irregularities. Instead, with Margolis’s apparent knowledge, the Department fired a member of the prosecution team who had blown the whistle on some of the misconduct. (“What the Justice Department is Hiding.”)

    Jeff Kaye collects a number of other occasions on which Margolis’s machinations have made their way into the media.

    In a July 6, 2008, Los Angeles Times story, Margolis is cited as leading an effort to avoid publication of the Department’s internal ethics reviews. Margolis told the Times that his opposition to publication of OPR reports was driven by concerns about “unnecessarily or gratuitously… publicly humiliating our line attorneys as individuals.” But it may well be that Margolis’s desire to keep his own role in those cases secret was a more pressing concern.

    There is little mistaking Margolis’s brief in all these matters. None of his critics fault Margolis’s own conduct as a lawyer. But they express concern that he is too quick to let political appointees off the hook and note that this has severely damaged the culture of the Justice Department. Ironically, Margolis is clearly driven by a desire to protect the Department’s reputation.

    Margolis’s decision to override the OPR’s lead investigator is just more of the same.

    P.S. For a nice critique of Margolis’s conclusion that Yoo did not act recklessly, see Brian Tamanaha’s post here.

  • Appeals Chamber Treats Dr. K Like Josef K

    by Kevin Jon Heller

    What a shock: the Appeals Chamber has upheld Richard Harvey’s appointment as stand-by counsel.  I would engage in a detailed account of its reasoning, but the short decision — 16 pages, only five of which are analysis — provides none.  Here, for example, is the AC’s response to the heart of Dr. Karadzic’s challenge, the irrationality of the procedures the Registrar used to select Harvey (para. 34):

    Karadzic fails to establish that the Trial Chamber inappropriately applied the Kvokca test.  In selecting Harvey as standby counsel, the Registrar considered a number of factors, including (i) conflicts of interest; (ii) availability for appointment as standby counsel; (iii) counsel having no reservations about being imposed; (iv) previous experience before the Tribunal; and (v) geographic proximity.  None of the specific examples of allegedly unfair  or arbitrary reasoning Karadzic  raises demonstrate that the Trial Chamber abused its discretion in finding that the Registrar appropriately exercised his discretion.  More specifically, the Appeals Chamber is satisfied that the Trial Chamber acted within its discretion in concluding that the Registrar’s application of pre-screening neither contravened any legal requirement nor was unfair or nonsensical.

    That’s it.  That’s the “analysis.”  No attempt to respond to any of Dr. Karadzic’s arguments, just brute force claims that everything is fine.  We’re the Appeals Chamber, we can do what we want.  Deal with it.

    That’s appalling, but I guess it’s also unsurprising.  After all, it’s not like the Appeals Chamber could have defended the procedures.  Indeed, I pity the poor judge who tried to actually explain how the Registrar’s conflict of interest requirement was neither “unfair or nonsensical,” even though the Registrar used it to exclude numerous barristers who did not have actual conflicts (because the requirement did not require actual adversity) and include one, Colleen Rohan, who did.  Were I the judge, I would have said “screw it, let’s just claim it all makes sense,” too.

    The Appeals Chamber should be embarrassed by its latest “decision.”  And anyone who cares about the legacy of the ICTY, no matter how they feel about Dr. Karadzic, should be ashamed that this is what now passes for “analysis” in the Tribunal’s final and most important case.  The stain that Judge Hunt decried years ago spreads ever wider with each passing day.

  • Come Work in the World’s Third Most Livable City!

    by Kevin Jon Heller

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    The Economist Intelligence Unit has just released its annual list of the world’s most livable cities — and my adopted home of Melbourne ranks third, behind only Vancouver and Vienna.  It thus seems like an appropriate time to mention that Melbourne Law School is looking to hire new faculty at all levels, from Lecturer to Professor:

    This year we are particularly interested in, and encourage, applications from scholars researching and teaching in the fields of administrative law; criminal law and evidence; media and technology law; and private law, in particular remedies and torts.

    We continue to seek new colleagues at all ranks (levels B to E) and across all sub-disciplines who share our commitment to a highly collegial, research-intensive professional life. We specifically encourage applications from current or aspiring academics with a clear understanding of the value of cross-disciplinary and comparative analysis, who are able to integrate teaching with research and knowledge transfer activities, and who are prepared to contribute to the vibrant communal life and culture at the Law School and within the University of Melbourne as a whole.

    Salaries are quite competitive with the US market, particularly with the Australian dollar hovering around $.92. The Lecturer range is AUD $73,863 to AUD $87,710; the Senior Lecturer range is AUD $90,480 to AUD $104,329; the Associate Professor range is AUD $108,946 to AUD $120,025; and the Professor range is AUD $140,335 and above.  Salaries also include a fantastic 17% superannuation — 17% of your salary paid directly to your retirement fund each year, on top of the salary itself.

    Potential applicants should be aware that it is very unlikely we will be hiring any pure international-law scholars — we already have more than a dozen on the faculty.  But I am confident that we would be delighted to hire someone who is genuinely committed to teaching one or more of the subjects identified above whose work is also international, transnational, or comparative in focus.  I was hired, for example, as a comparative criminal-law person; I teach two or three streams of Australian criminal law each year in addition to ICL.  (And love doing so.)

    I can’t say enough good things about Melbourne as a city or Melbourne Law School.  It would be an exciting time to join the faculty, as we are about two years away from becoming a graduate-only law school — Australia’s first.

    If anyone is seriously interested in applying, feel free to drop me a line with any questions: [email protected]. More details on the vacancies are available here.

  • Criminal Libel for Publishing a Critical Book Review? Seriously?

    by Kevin Jon Heller

    That’s the allegation made by Dr. Karin N. Calvo-Goller, a senior lecturer at the Academic Center of Law & Business in Israel, against Joseph H.H. Weiler, a professor at NYU who is the Editor-in-Chief of the marvelous European Journal of International Law.  In 2007, globallawbooks.org (GLB), a book-review website associated with EJIL that Professor Weiler also edits, published a negative review of Dr. Calvo-Goller’s book The Trial Proceedings of the International Criminal Court: ICTY and ICTR Precedents written by Professor Thomas Weigend, who is the Director of the Cologne Institute of Foreign and International Criminal Law and currently the Dean of the University of Cologne’s Faculty of Law.  Dr. Calvo-Goller responded by writing a letter to Professor Weiler in which she claimed that Professor Weigend’s review was libelous and demanded that Weiler remove the review from the GLB website.  Professor Weiler patiently addressed each of Dr. Calvo-Goller’s criticisms of the review and — not surprisingly — refused to remove it.  He did, however, offer to publish Dr. Calvo-Goller’s response alongside Professor Weigend’s review.

    More than a year later, Dr. Calvo-Goller filed a complaint in a French court accusing Professor Weiler of criminal libel.  As a result, Professor Weiler is scheduled to stand trial on June 25.  The fact that he will stand trial does not mean that the court has found Dr. Calvo-Goller’s complaint meritorious; according to Professor Weiler, the Examining Judge explained to him that “unlike other areas of the criminal law she had no discretion to examine the merits of the complaint…  [I]n libel cases, all investigations of the merits of the case are exclusively reserved for the Criminal Court itself and, therefore, as a direct consequence of the complaint being filed, it was necessary that I be referred to the Court for trial.”

    With due respect to French law, it is shocking that a defendant can be forced to suffer the time, expense, and emotional strain of a criminal trial based solely on an unexamined libel complaint.  But it is even more shocking — and completely indefensible — that Dr. Calvo-Goller would submit the complaint in the first place. Although I have not read her book, I have read Professor Weigend’s review of it and Professor Weiler’s subsequent correspondence with her.  (Which is available here.)  The review is actually quite mild (and only four paragraphs long) — Dr. Calvo-Goller obviously has very thin skin.  More importantly, insofar as Professor Weiler accurately recounts them, her criticisms of the review seem to be completely without merit. To begin with, none of the factual claims in Professor Weigend’s review actually appear to be false.  At most, the review and Dr. Calvo-Goller’s response reflect legitimate differences of opinion over various difficult issues in international criminal law.

    Moreover, insofar as any of Professor Weigend’s claims might be deemed false, Dr. Calvo-Goller presents absolutely no evidence that he made them knowing of their falsity.  Indeed, anyone who knows Professor Weigend — as I do; he wrote the Germany chapter for my forthcoming Handbook of Comparative Criminal Law — could not possibly believe such a ridiculous allegation.  Professor Weigend is a superb scholar and an unfailingly generous person. I cannot imagine that he would ever deliberately try to harm a scholar’s reputation, no matter what he thought of that person’s work.  (And again, the review is not particularly critical.)

    Finally, speaking as someone who was the book-review editor of the New Criminal Law Review for nearly two years, I think it is safe to say that regardless of Dr. Calvo-Goller’s opinion of Professor Weigend’s review, there is absolutely no justification for filing criminal charges against Professor Weiler, who simply published the review. A more direct attack on academic freedom is difficult to imagine.  Book-review editors have to be free to publish negative reviews; it is impossible to take seriously a journal that only publishes reviews of books its reviewers like.  Shilling for a book is the publisher’s responsibility; the responsibility of a book-review editor is to commission a suitable expert to review the book and then to publish that review regardless of whether it is positive or negative.

    Despite the evident problems with France criminal-libel laws, I have enough faith in the French criminal-justice system to assume that Dr. Calvo-Goller’s complaint will go nowhere.  And I know for a fact that Professor Weiler’s reputation is sufficiently sterling that he will emerge unscathed from this whole sordid affair.  But it is still appalling that he has to suffer the affair in the first place.  Shame on Dr. Calvo-Goller for her petty thuggery.

  • ICJ Seeking Clerks!

    by Kevin Jon Heller

    The Administration and Personnel Division at the International Court of Justice has asked us to inform our readers that the Court is looking to hire new clerks.  According to the announcement, the General Assembly has assigned the Court six additional clerkship positions, permitting each judge to have a full-time clerk of his or her own.  The vacancy announcement can be downloaded here; the link to the ICJ’s vacancy page is here; and here are some of the particulars:

    Functions: Under the supervision of the judge to whom he or she will be specifically assigned, the Law Clerk will provide such judge with legal research and related assistance with regard to cases pending before the Court. The Law Clerk may also be required to provide legal assistance and support to a judge ad hoc participating in a particular case. In coordination with his or her judge, the Law Clerk may also from time to time be called upon to perform some specific legal tasks for the Registry.

    Qualifications and skills: university degree in law, with significant academic background in public international law or professional experience in the field. Graduate and/or post-graduate studies in public international law would be an asset; two years’ experience in the settlement of international legal disputes with an international organization, government, law firm or other private sector entity would be desirable.

    Languages: French and English are the official and working languages of the Court. Excellent knowledge of and drafting ability in one of these languages is required, as well as a working knowledge of the other. Command of other official languages of the United Nations would be an asset.

    Needless to say, this is an amazing opportunity for recent law graduates.  The ICJ clerks I know have all had an amazing time.  The clerkships, which last two years, are even well paid — more than 50,000 euros per year.  The deadline to apply is April 6.

    PS.  Perhaps it’s because I’m used to the US clerkship system, I find it more than a little remarkable that the ICJ judges have never had full-time clerks of their own until now.

  • New Law Review Partner — Melbourne Journal of International Law

    by Kevin Jon Heller

    I am delighted to announce that Opinio Juris has formed a partnership with the Melbourne Journal of International Law, one of the leading non-US journals in the field.  Twice a year, beginning tomorrow, we will be hosting the same kind of symposia that we have been holding the past couple of years for the Yale Journal of International Law and the Virginia Journal of International Law.  Unlike those journals, MJIL is student-run but peer-reviewed.  The first symposium will feature two articles from the most recent issue of the journal.

    The editors of MJIL will be introducing the journal and the articles tomorrow.  I hope our readers will enjoy the symposium.

  • Jewish Praise for Inglourious Basterds

    by Kevin Jon Heller

    Eight Oscar nominations and accolades at the Museum of Tolerance — not a bad week for Mr. Tarantino:

    Last night at a special community screening at The Simon Wiesenthal Center Museum of Tolerance, internationally renowned rabbi Marvin Hier addressed the film’s growing cultural significance among a panel that included Tarantino, ‘Basterds’ producer Lawrence Bender, actor Eli Roth and media entrepreneur Dan Adler, who organized the evening in honor of his recently deceased father Mayer Michael Adler, a survivor of the Auschwitz concentration camp.

    “Let me explain why I think it was a great idea to sponsor this film,” Hier said, addressing concerns from Holocaust survivors who were troubled by some of the film’s subject matter. “Not every film on the second World War has to be about the Holocaust.”

    No one would argue that “Inglourious Basterds” is a traditional Holocaust movie, but it does presume a sophisticated knowledge of the Holocaust in order to grasp its emotional impact. Hier, who is an Oscar-winning filmmaker himself, said that historical accuracy is not a necessity in harnessing the power of cinematic fantasy. “This [film] has a certain release factor,” he said. “If only we would have been privileged to see the Nazis defeated early on; imagine that they were all gathered in a theater and we didn’t have to roll the clock until 1945 to find out that 6 million Jews plus millions of other individuals were killed by an insane man named Adolf Hitler.”

    For many Jews, including Hier, the fact that ‘Basterds’ permits not only historical revisionism but also deep seeded Jewish revenge is psychologically satisfying. “I find it to be quite exciting,” Hier said. “The plot I thought was quite ingenious.” Though he did point out that there were, historically, several failed attempts on Hitler’s life, so the idea of an assassination mission is not implausible. Hier also spoke of Pinchas Rosenbaum, the son of a rabbi whose family was killed in Auschwitz and who successfully infiltrated the SS to avenge them.

    I know this is not a uniform reaction — many Jews, particularly here in Melbourne, thought that the film made light of Hitler and the Holocaust.  Readers are no doubt aware that I rarely like Holocaust movies.  But I loved Inglourious Basterds, for the same reasons as Rabbi Hier.

    I’m just starting to write the “Aftermath” chapter of my book, which discusses the gradual erosion of the US’s commitment to the war-crimes program following the end of the NMT.  The villain in the story is John J. McCloy, the High Commissioner of Germany — who in addition to setting nearly all of the NMT convicted free by the early 1950s, was also one of the US officials who had turned down Jewish requests to bomb Auschwitz on the ground that doing so was “impracticable” and would divert necessary resources from “decisive operations elsewhere.”  Recent research indicates that, contrary to McCloy’s position, Allied bombers could have reached Auschwitz and the rail lines leading to the camp any time after June 1944 — and that an attack could have considerably slowed the killing process, saving perhaps some 400,000 Hungarian Jews.

    If only McCloy and the other US officials had shown Tarantino’s creativity…

  • The Pushback Against the Appeals Chamber Begins

    by Kevin Jon Heller

    I intend to closely follow the reactions to the Appeals Chamber’s decision on the genocide charges against Bashir.  The pushback has already begun in a predictable place: the Making Sense of Darfur blog, which has led the charge against the arrest warrant. The post itself, in which David Barsoum asks “what is the ICC really after in Sudan?”, is not particularly noteworthy, because the answer is straightforward: accountability for a mass murderer who has done everything he could for nearly two decades to prevent any kind of peace that would threaten his regime.  More interesting — and more troubling — is Alex de Waal’s comment to Barsoum’s post.  He writes:

    This episode at the ICC is somewhat bizarre. In March last year, the pre-trial chamber issued the arrest warrant that the Prosecutor had requested. This made Pres. Bashir into a fugitive from justice. The crimes for which he is charged are no less heinous than genocide. Any additional charges added subsequently make absolutely no difference to that reality. The Prosecutor’s decision to appeal against the exclusion of the genocide charges, while perfectly permissible in law, served only the purpose of satisfying the personal or political ambition of the Prosecutor. If the ICC ever succeeds in getting Pres. Bashir in Court, the Prosecutor can then add whatever charges he believes are warranted by the evidence. Insisting on them at this stage is a political act.

    None of Alex’s claims are compelling.  First, it is difficult to seriously maintain that there is no difference between charging someone with crimes against humanity and genocide.  There may be no difference in terms of the maximum possible sentence, but it clear that genocide is viewed as far more serious than even the crime against humanity of extermination.  That’s why Raphael Lemkin coined the term “genocide.”  That’s why we have a Genocide Convention.  That’s why activists and scholars and governments put so much energy into ensuring that various situations — Saddam’s gassing of the Kurds, the Khmer Rouge’s “auto-genocide,” China’s treatment of Tibet, Australia’s treatment of aboriginals, etc. — are (or are not) labeled genocide instead of “mere” crimes against humanity.  Perhaps it is regrettable that we rank international crimes, but there is no question that we do.  Indeed, if Alex genuinely believed there was no difference between genocide and crimes against humanity, he would not have spent so much time and energy over the past year attempting to rebut the claim that Bashir committed genocide.  He admits that Bashir committed crimes against humanity on a massive scale, so if there is no difference, why bother to oppose describing the situation in Darfur as genocidal?

    (There is, of course, an important theoretical justification for viewing genocide as more serious.  The identity of the victims is irrelevant in the crime against humanity of extermination; any mass killing will suffice.  In genocide, by contrast, the victims are singled out for extermination because they are members of a particular racial, ethnic, religious, or national group.  Genocide is thus more serious than extermination in two ways: (1) the crime threatens the existence of a particular protected group, a result that would reduce human diversity; and (2) the victims are specifically targeted for extermination by the perpetrator, a more culpable mental state than the one required by extermination, which is simply the intent to kill.)

    Alex’s second claim — that the decision to appeal the Pre-Trial Chamber’s decision on the genocide charges “served only the purpose of satisfying the personal or political ambition of the Prosecutor” — is simply incorrect.  The Pre-Trial Chamber completely misunderstood Article 58’s “reasonable grounds” standard, leading it to wrongly exclude the charges.  Whatever one thinks of the genocide charges against Bashir — and Moreno-Ocampo is far from the only person who supports them — the OTP could not permit the Pre-Trial Chamber’s flawed standard to go unchallenged, because it would have almost certainly come back to haunt the office in other cases involving different charges.  As the Appeals Chamber noted in its decision (para. 33), “requiring that the existence of genocidal intent must be the only reasonable conclusion amounts to requiring the Prosecutor to disprove any other reasonable conclusions and to eliminate any reasonable doubt.”  In other words, the Pre-Trial Chamber effectively converted the “reasonable grounds” requirement into a requirement of “proof beyond a reasonable doubt,” the standard that applies at trial, not at the arrest warrant stage.  That erroneous interpretation of “reasonable grounds” was not limited to the Bashir case or to the genocide charges; it represented the Pre-Trial Chamber’s first sustained interpretation of Article 58.  The OTP thus had to challenge it.

    That explanation of the OTP’s decision to appeal helps rebut Alex’s third claim, which is that we can conclude that the decision was a “political act,” because “[i]f the ICC ever succeeds in getting Pres. Bashir in Court, the Prosecutor can then add whatever charges he believes are warranted by the evidence.”  Adding the genocide charges later would not address the mischief created by the Pre-Trial Chamber’s erroneous interpretation of Article 58.  Moreover, seeking to amend the arrest warrant is far more fair to Bashir (or to any defendant in like circumstances) than waiting until the confirmation of charges hearing, because it puts him on notice now — not months or years from now — that he will be facing genocide charges.  Bashir is going to be a fugitive from justice either way, so isn’t it better for all the charges to be on the table as early as possible?  I can only imagine the outcry from Bashir supporters and defense attorneys (including me) if the OTP had never mentioned genocide charges until Bashir was standing in front of the Pre-Trial Chamber!

    Critics of the ICC often claim that the Court pays insufficient attention to politics.  I think it’s safe to say that most of those critics pay insufficient attention to law.

    UPDATE: At his NUI-Galway blog, Bill Schabas, one of the great ICL scholars, goes even further than Alex, writing that “This is all much ado about nothing. Given the close overlap between genocide and crimes against humanity, even with the existing arrest warrant the Prosecutor would be unconstrained in producing relevant evidence that might lead to a conclusion that genocide was taking place. The judges would be relatively free to add a conviction for genocide, if they thought it appropriate.”  I have to respectfully disagree.  I think it would be a terrible prosecution strategy to adduce evidence that supports a conviction for genocide during trial and then hope that the Trial Chamber enters a conviction for genocide even though it wasn’t charged.  After all, the Appeals Chamber very recently rejected a similar “recharacterization” of the evidence in Lubanga, refusing to add new crimes against humanity charges because the “facts and circumstances” in the confirmation of charges did not support them, thereby violating Article 74(2) of the Rome Statute.  I simply fail to see how, if Bashir went to trial only on the war crimes and crimes against humanity charges, the “facts and circumstances” in the charging document would support “recharacterizing” them to support a genocide conviction, given genocide’s objective requirement that the targeted individuals be members of a protected group and its subjective requirement that the defendant have specifically intended to destroy the protected group as such.  Frankly, Alex’s suggestion — that the OTP seek to amend the charges once Bashir was arrested but before trial — would be the lesser of two evils.

  • Breaking: Pre-Trial Chamber Must Reconsider Genocide Charges Against Bashir

    by Kevin Jon Heller

    As I predicted, the Appeals Chamber has rejected the Pre-Trial Chamber’s interpretation of the “reasonable grounds” standard:

    Appeals judges said the court was wrong to conclude in March that there was insufficient evidence to merit charging al-Bashir with three genocide counts. Instead, it had charged him with seven counts of war crimes and crimes against humanity for allegedly orchestrating a campaign of murder, torture, rape and forced expulsions in Darfur province.

    The standard of proof the court sought for genocide charges “was higher and more demanding than what is required” in its statutes, appellate judge Erkki Kourula of Finland said Wednesday.

    The decision likely paves the way for al-Bashir to be indicted with humanity’s worst crime – attempting to wipe out entire ethnic groups in the war-ravaged province.

    I will have much more to say about the decision soon.  The decision is available here.

    POSTSCRIPT: I’m glad the Appeals Chamber reached the correct conclusion, but it’s absurd that it took them nearly eight months to issue an 18-page decision (13 of which are simply background).  This was — at least from a legal perspective — an easy issue.  The AC should not have kept the OTP, Bashir, and the rest of the world hanging so long.

  • Thoughts on Glennon’s “Blank-Prose Crime of Aggression”

    by Kevin Jon Heller

    I want to offer two thoughts on Glennon’s article, which — though I am generally skeptical of the ICC’s attempts to define the crime — I find anything but convincing.  The first has to do with his central thesis: that the Special Working Group on the Crime of Aggression’s proposed definition of aggression “would constitute a crime in blank prose — one that would run afoul of basic international human rights norms and domestic guarantees of due process in its disregard of the international principle of legality and related U.S. constitutional prohibitions against vague and retroactive criminal punishment” (p. 72).  Readers should be skeptical of that thesis for many reasons, but one reason looms particularly large — Glennon does not even mention, much less discuss, the SWG’s proposed elements of the crime of aggression.  The Elements of Crimes were adopted precisely to minimize nullum crimen problems with the definitions of crimes in the Rome Statute, and they remain perhaps the most positive legacy of the US’s involvement in the establishment of the ICC.

    The SWG has debated the elements of the crime of aggression for a number of years.  The most recent formulation was distributed in a 28 May 2009 non-paper by the Chairman:

    Article 8 bis
    Crime of aggression

    Introduction
    1. It is understood that any of the acts referred to in article 8 bis, paragraph 2, qualify as an act of aggression.
    2. As a result of Element 4, there is no requirement to prove that the perpetrator has made a legal evaluation as to the inconsistency with the Charter of the United Nations of the use of armed force by the State.
    3. With respect to Elements 5 and 6, the term “manifest” is an objective qualification.
    4. As a result of Element 6, there is no requirement to prove that the perpetrator has made a legal evaluation as to the “manifest” nature of the violation.

    Elements
    1. The perpetrator planned, prepared, initiated or executed an act of aggression.
    2. The perpetrator was a person in a position effectively to exercise control over or to direct the political or military action of the State which committed the act of aggression.
    3. The act of aggression – the use of armed force by a State against the sovereignty, territorial integrity or political independence of another State, or in any other manner inconsistent with the Charter of the United Nations – was committed.
    4. The perpetrator was aware of the factual circumstances establishing the inconsistency of the use of armed force by the State with the Charter of the United Nations.
    5. The act of aggression, by its character, gravity and scale, constituted a manifest violation of the Charter of the United Nations.
    6. The perpetrator was aware of the factual circumstances establishing such a manifest violation of the Charter of the United Nations.

    Glennon may very well believe that these elements do not cure the crime’s supposed nullem crimen problems.  I might even be sympathetic to his critique — I’ve made my problems with the proposed elements known to the Australian delegation to the SWG.  But I cannot see how anyone can claim that the crime of aggression is impermissibly vague without even addressing the proposed elements.  Indeed, it appears that Glennon does not even realize that they exist.  How else do we explain his statement that “[p]otential defendants have a right to know the specific elements of a crime before their conduct occurs — not when they are charged or tried, after a consensus has finally emerged” (p. 111-12)?  If the Assembly of States Parties adopts a definition of aggression, they obviously will.

    The second thought concerns Glennon’s claim that customary international law does not criminalize aggression (p. 74).  That is a truly bizarre position — and perhaps not surprisingly, Glennon cites only himself in defense of it.  (The footnote on p. 74 refers to footnote 129, which mentions Glennon’s book Limits of Law, Prerogatives of Power, and to footnote 165, which mentions the same book and Glennon’s article “How International Rules Die.”)  The London Charter, the Tokyo Charter, and Control Council Law No. 10 all criminalized aggression, and individuals were convicted of aggression under all three.  Those international instruments — as Gerhard Werle, one of the world’s most eminent ICL scholars has pointed out – “are the starting points for the established opinio juris of the international community that waging aggressive war is criminal.”  UN General Assembly Resolution 95(I), enacted on 11 December 1946, expressly affirmed that aggression is an international crime.  Article 5(2) of the UN Definition of Aggression and Principle 1(2) of the Friendly Relations Declaration both define aggression as a crime against peace.  The ILC took the position that aggression is an international crime in both the 1991 and 1996 Draft Codes of Crimes Against the Peace and Security of Mankind.  And, of course, aggression was included in the Rome Statute, “an expression of a belief in its criminality under customary international law.”

    To be sure, there is significant debate about the contours of the customary crime of aggression.  Some scholars adopt the conservative view that only acts of aggression equivalent to the acts condemned at Nuremberg and Tokyo can be considered criminal under international law — namely, those that are designed to annex territory or control the resources of the invaded state.  (This problematizes considering the invasion of Iraq to be criminal, unless one believes that the invasion was intended to control Iraq’s oil resources.)  Others take the view that customary international law criminalizes any act that violates Resolution 3314, the UN Definition of Aggression.  I take the former position, because I’m conservative when it comes to principle of legality issues.  But it’s a debatable point.  What is not debatable, though, is that at least some acts of aggression are criminal under customary international law.  For Glennon to claim otherwise illustrates just how radically conservative his views really are.

    I agree with Ken that Glennon’s article is interesting and well worth a read.  But readers would be well advised to take his conclusions with a very large grain of salt.

  • The Great Patriotic War — In Sand

    by Kevin Jon Heller

    If you haven’t seen this already, you should. The eight-minute video shows the winner of Ukraine’s Got Talent, 24-year-old Kseniya Simonova, dramatizing the effect of Operation Barbarossa on the Ukraine through a series of drawings on an illuminated sand table. It is absolutely mesmerizing — beautiful, disturbing, moving. As you will see, many members of the audience were in tears. So was I when I watched it.

    Hat-Tip: My mom.