Our research suggests that a sniper from Munich and a sniper
from Illinois may have killed unarmed Palestinian men in the
Gaza Strip – presumably civilians. Is there any scenario in
which such an action could be legally justified?
Tom Dannenbaum:
Having reviewed the footage, the videos do not appear to show that
the individuals concerned were armed or otherwise participating
directly in hostilities. Targeting individuals who are not
participating directly in hostilities or serving in a combat
function within an organized armed group would be a violation of
international humanitarian law. In this case, the available
evidence points to a war crime.
The Israeli military has repeatedly issued evacuation orders for
parts of the Gaza Strip, including the area where the men were
apparently shot. The Israeli army seems to no longer consider
people who disobey these orders or remain in the areas to be
civilians, but rather combatants. Is such action legally
tenable?
Tom Dannenbaum:
No, such a practice would violate international law. The legal
requirement to issue advance warnings and the legal permission to
issue evacuation orders in limited circumstances are provided to
protect the civilian population – not to authorize shooting at
them, if they remain behind. Those who stay are still civilians
and retain all of the legal protections associated with that
status. International humanitarian law requires that only
legitimate military targets may be attacked – and only in a
proportionate manner. Warnings do not release anyone from this
obligation. If civilians are still present in an area, which is
regularly the case, their protection must continue to be
guaranteed. Anyone who then indiscriminately attacks people in the
remaining population is directing attacks against civilians and
thus committing war crimes.
One of the snipers – the man from Illinois – claimed in an
interview that the men who were killed had crossed an invisible
line and had therefore become legitimate targets. What do you
think of this argument?
Tom Dannenbaum:
It is simply wrong. Civilians may only be attacked if they are
directly participating in hostilities, for example, if they take
up arms. Merely crossing an imaginary line does not change a
person's legal status, nor does it constitute participation in
hostilities.
One of the men who was shot apparently tried to recover a body.
Purely hypothetically, would it be different if the dead man had
been a known Hamas commander?
Tom Dannenbaum:
No. Attempting to recover a body does not constitute direct
participation in hostilities. The recovery of dead bodies is
protected under international law. Even if the deceased had been a
combatant, for which there appears to be no publicly available
evidence in this case, that does not make anyone who wants to
recover the body a legitimate target.
The soldier speculated in an interview that the man who was shot
might have been seeking to recover important documents from the
pockets of the person who was killed…
Tom Dannenbaum:
This appears to be a speculative factual claim, both in terms of
whether the killed person had documents and whether the other
individual was seeking to retrieve them. Even if it were true,
absent specific information about the direct significance of the
documents to military operations, collecting documents would not
itself entail participating directly in hostilities. If such an
argument were accepted, militaries could justify killing just
about any civilian based purely on speculation regarding what they
might be doing and how that might be related to military
operations. From an international law perspective, that's
indefensible. Under international humanitarian law, when there is
doubt as to a person’s status, they must be considered to be a
civilian.
In recent months, there have been numerous allegations against
the Israeli military: hospitals and media offices are said to
have been deliberately targeted, as well as aid convoys and
entire villages deliberately destroyed. The military regularly
refers to internal investigations, but rarely provides details
of which cases are being examined. In the case of the two
snipers, the military refuses to provide any information. Could
courts outside Israel, such as the International Criminal Court,
take up the case?
Tom Dannenbaum:
The International Criminal Court has jurisdiction over war crimes
occurring in Gaza due to Palestine’s accession in 2015. That said,
it is a court of last resort. Therefore, if its Prosecutor were to
pursue such a case, the Court would examine whether there is or
was a "genuine" investigation in a country with jurisdiction –
that is, an investigation that is independent, serious, and
focused on the same person and same criminal conduct as that
alleged by the Prosecutor. If this is not the case, the ICC can
take action. For example, the ICC issued arrest warrants against
Israeli Prime Minister Benjamin Netanyahu and former Defense
Minister Yoav Gallant because there was no Israeli criminal
investigation into allegations that those individuals were
responsible for war crimes and crimes against humanity relating to
starving the civilian population in Gaza.
Germany has made a name for itself in applying the principle of
universal jurisdiction, for example in trials against Syrian
torturers or African warlords. However, it has shown remarkable
restraint when it comes to alleged Israeli war crimes. Now one
of the snipers who allegedly shot civilians is registered in
Munich. Do German prosecutors have an obligation to act here?
Tom Dannenbaum:
Yes, absolutely. If a suspect is on German territory or is a
German citizen, Germany's authorities are obliged under the Geneva
Conventions and Additional Protocol I to initiate investigations.
More broadly, they are required to cooperate with other states
engaged in war crimes investigations, including in this case.
Criminal lawsuits have been filed in Europe against soldiers who
served with the Israeli military. Are such criminal prosecutions
possible in the US and what would that process look like?
Tom Dannenbaum: It is possible for soldiers who
served in the Israeli military to be prosecuted in the United
States for war crimes. However, there are some notable constraints
on the US process.
First, for war crimes occurring outside the US, one of two things
needs to be true: either the alleged offender must be present in
the US, or the perpetrator or victim must have been a US national,
US permanent resident, or member of the US Armed Forces. This is
narrower than some European states’ universal jurisdiction
doctrines, such as Germany’s.
Second, the list of war crimes codified in US law is significantly
more limited than that of many European states. This is due to the
US legislation’s focus on grave breaches of the four Geneva
Conventions and a very short additional list of crimes (including
certain serious violations of Common Article 3). European states,
however, are also party to Additional Protocol I of 1977, which
includes a longer list of grave breaches. Most of the crimes at
issue in our conversation are either war crimes under customary
international law (including as serious violations of Common
Article 3) or grave breaches of the Geneva Conventions.
Finally, under domestic US law, war crimes prosecutions may only
go ahead with the certification of the Attorney General (or
certain specified subordinates) that a prosecution by the United
States is in the public interest and necessary to secure
substantial justice. If US jurisdiction depends on the alleged
offender’s presence in the US (rather than the perpetrator’s or
victim’s nationality, residency, or US armed forces membership),
the Attorney General or Deputy Attorney General must also consider
whether removal for prosecution elsewhere is possible and
“potential adverse consequences for nationals, service members, or
employees of the United States.” These are significant
limitations, particularly under current political conditions.
How does the Justice for Victims of War Crimes Act, signed in
Jan 2023, affect US jurisdiction to prosecute war crimes?
Tom Dannenbaum: It has been possible since the
passage of the War Crimes Act in 1996 for US courts to hear cases
involving alleged war crimes perpetrated abroad. However, prior to
the Justice for Victims of War Crimes Act in 2023, this was
possible only when the perpetrator or the victim was either a US
national or a member of the US Armed Forces.
The Justice for Victims of War Crimes Act amended that
jurisdictional constraint. Today, US courts can also hear
extraterritorial war crimes cases when the alleged offender is
present in the United States.
This is an alternative to jurisdiction based on the crime being
perpetrated by or against a US national, US permanent resident, or
member of the US Armed Forces. Both of those are alternatives to
the most obvious jurisdictional basis, which would be the crime
occurring in the US.
How did it affect the prosecution of individuals, especially in
cases involving US nationals?
Tom Dannenbaum: The prosecution of US nationals
for war crimes committed abroad was possible even before the
Justice for Victims of War Crimes Act. However, the 2023
legislation covers war crimes by or against US permanent
residents, not only US nationals or members of the US Armed
Forces.
A criminal case against a specific individual would need to be
established beyond reasonable doubt in court. It is the
prosecutor’s burden to meet that threshold, including, for
example, on the issues of the individual’s contribution and their
mental state at the time.
There are several possible war crimes implicated in directing
lethal attacks at persons solely on the basis of their location,
age, and gender. The most obvious would be directing attacks
against civilians, knowing that there was, at a minimum, a
substantial and unjustifiable risk that the targets were
civilians.
This is codified as a grave breach of Additional Protocol I and as
a war crime in the Statute of the International Criminal Court.
Although the US is not party to those treaties, this prohibition
is also a war crime under customary international law, which
applies to all states, including the United States. Nonetheless,
it is not currently codified in US war crimes legislation.
Therefore, if charges were brought forward regarding any
individual involved in indiscriminate sniping, the likely charge
under US war crimes legislation, would be murder of a person
taking no active part in hostilities.
An alternative would be willful killing as a grave breach of
Geneva Convention IV (predicated on the occupation of Gaza), but
this may be less likely, as it would implicate technicalities that
would not arise in the alternative framing. Under the murder
category, the key question regarding purposefully lethal actions
would be whether the perpetrator acted with recklessness regarding
whether the target was taking no active part in hostilities.
Purposefully firing lethal rounds at persons solely on the basis
of their location, gender, and age would properly be understood to
meet that threshold.
"The available evidence points to a war crime"
After reviewing videos of the incidents, International law expert Tom Dannenbaum believes the US and Germany have an obligation to investigate snipers who are seen in videos that appear to show shooting unarmed people in the Gaza Strip.