Wednesday, July 30, 2014

Human Shields in International Humanitarian Law and in Domestic Criminal Law

by Michael Dorf

As I post these thoughts, there is no ceasefire in place to stop the immediate bloodshed in Gaza and Israel, much less any apparent progress towards resolving the larger conflict. But, as with my most recent post inspired by the latest outbreak of violence, I am going to address a general issue it raises, rather than assess the current situation or the broader conflict. I realize that in treating a very real tragedy as merely the insipiration for an intellectual discourse, I risk coming across as detached or unfeeling, so let me assure readers that I take very seriously both Israel's security concerns and the devastation in Gaza. As with my last post on the current Israel/Hamas conflict, I want to discourage comments on topics other than the one I address here, and to announce in advance that I won't respond to any such off-topic comments.

With that warning/disclaimer out of the way, I come to the question that concerns me: Can we learn anything about the human shields question in international humanitarian law (IHL) by looking at domestic criminal law?

The issue is inspired by a question that I bracketed in my last post on civilian casualties: If Force A uses human shields, does that affect the determination of whether Force B's use of force against A is proportionate (and thus legal)? Israel says that Hamas deliberately embeds itself in the civilian population, storing and launching rockets from, and digging tunnels under schools, hospitals, and mosques, as well as preventing some Gaza civilians from heeding Israeli warnings to evacuate targeted buildings--and that therefore, the proportion of civilian casualties from Israel's attacks on Hamas should be permissible even if that proportion is higher than the threshold that would lead to the conclusion that Israel would be violating the proportionality norm absent the deliberate use of human shields.

One could contest various premises here. For one thing, Hamas is not exactly the government of a country, and so the application of IHL to it is open to question. Nor is it entirely clear that IHL, as opposed to the stricter norms applicable to occupying forces, applies to Israel with respect to Gaza. Although Israel dismantled all of its Gaza settlements in 2005, Gaza remains subject to considerable Israeli (and also Egyptian) control. In addition, Hamas and others argue that the population density of Gaza, rather than its deliberate policies, are mostly responsible for the high civilian casualty rates.

These and other issues would need to be addressed in any assessment of war crimes liability for Hamas and/or Israel, but I'm going to put them aside here to focus on a general issue that arises in many asymmetrical conflicts: Does the measure of proportionality in determining the lawfulness of attacks that foreseeably lead to collateral civilian casualties change when the enemy uses civilians as human shields? (There is some disagreement about what exactly it means for a force to use human shields, but I use the term loosely to refer to any actions deliberately undertaken to ensure that attacks by the enemy on military targets will likely result in substantial civilian casualties.)

Since writing my last post, I did a bit of research and came to the conclusion that IHL is not fully determinate on the question, but is probably best read as not changing its definition of proportionality based on the use of human shields by the enemy. The basic idea appears to be that war crimes by one side don't justify war crimes by the other.

That logic has been questioned. For example, a Student Note in the 2012 Vanderbilt Journal of Transnational Law argues that IHL should give the attacking side the right to disregard human shields entirely, on the ground that this approach, if followed consistently, would reduce the incentive for the enemy to use human shields in the first place. For what it's worth, I think that's probably wrong even on its own terms. Even if foreseeably killing unlimited numbers of human shields were lawful under IHL, many countries would refrain from doing so out of moral and/or public relations considersations, and so there would remain an incentive for the other side in a conflict to use human shields.

A less extreme reform proposal comes from Amnon Rubinstein and Yaniv Roznai in the 2011 Stanford Law and Policy Review. They argue first that IHL ought to be clearer that forces deploying human shields commit grievous war crimes. Next, they urge distinguishing between voluntary human shields and involuntary ones; people who volunteer to serve as human shields should not count as civilians for purposes of calculating proportionality (as civilians participating in hostilities ordinarily do not so count during the period of their participation); but given the difficulty of determining whether particular individuals are voluntary or involuntary shields, uncertainty should be resolved with a presumption in favor of treating human shields as involuntary, and thus protected. Finally, Rubinstein and Roznai would retain the proportionality requirement as against an enemy employing involuntary human shields, but they would relax it somewhat. Thus (and this is my account of their proposal), if for some military operation, the proportionality limit on the number and severity of civilian casualties would be X in the absence of human shields, it would be X+Y if the enemy is using involuntary human shields.

I think there is much to be said for the Rubinstein/Roznai proposal but also much to be said for the two-wrongs-don't-make-a-right logic of the current IHL norm (as I perceive it). I do not start out with a strong view about which approach is to be preferred in IHL, but perhaps we can get some guidance from the parallel question in domestic criminal law.

Hostage-taking is a close cousin of the use of human shields in domestic criminal law, but its usual logic is importantly different. If bank robbers hold customers and bank employees hostage in order to facilitate their own escape, they are using the hostages as shields, but the robbers usually aren't threatening violence to anyone else, so it is difficult to imagine a scenario in which one might think that intentionally killing the bank robbers while foreseeably but regrettably killing the hostages makes any sense.

It is difficult to come up with a realistic scenario in domestic crime that closely parallels the IHL case. (For an unrealistic scenario, I recommend the boat scene from the Batman film The Dark Knight). But realistic or not, here is what I have in mind: Bad Guy, with the intent to kill Good Guy, has a gun pointed at Good Guy, who also has a gun, but Bad Guy is holding Innocent Shield in front of him, so that the only way that Good Guy can shoot Bad Guy before Bad Guy shoots Good Guy (who cannot safely retreat) is by shooting in a way that will foreseeably (albeit regrettably) harm or kill not just Bad Guy but also Innocent Shield. Is Good Guy permitted to shoot?

Notice that in my hypothetical example, Good Guy wants to use deadly force to protect himself. I am not asking whether a police officer would be justified in shooting. I think the answer to that question would generally be no, even if Good Guy would be permitted to shoot: A police officer would have no reason to prefer the life of Good Guy to Innocent Shield--although a police officer might have reason to think that there's at least a chance that he could hit Bad Guy without harming Innocent Shield, and so conclude that there will be a lower chance of the loss of innocent life if he shoots than if he doesn't. But let's put that issue aside. Although one could analogize the use of force by countries in war to the use of force by police, more commonly national self-defense is analogized to individual self-defense.

So, can Good Guy use deadly force against Bad Guy, knowing that there is a substantial probability that in doing so he will also kill Innocent Shield? Put differently, suppose Good Guy does use deadly force in this way, resulting in the death of both Bad Guy and Innocent Shield. Will he face criminal liability?

Let's look at the answer under the New York Penal Law (which pretty closely follows the Model Penal Code; the answer may differ in other states, but not that much, I suspect). Prima facie, Good Guy has committed two second-degree murders because he acted intentionally with respect to Bad Guy and at least extremely recklessly with respect to Innocent Shield. (Alternatively, Good Guy might be on the hook for Innocent Shield under a "transferred intent" theory.) Under NY Penal Code Sec. 35.15, Good Guy can make out a successful defense of justification (i.e., self-defense) with respect to Bad Guy, but not with respect to Innocent Victim, because self-defense only applies against the attacker himself. Is there some other defense available?

Duress is arguably a possibility. In the standard duress scenario, X uses duress to induce Y to commit an offense against Z. (E.g., "mug that old lady or I'll break your knees"), but we can imagine that the threat that Bad Guy poses to Good Guy would be the duress that leads Good Guy to kill Innocent Shield. (Joshua Dressler proposes that Model Penal Code duress would be an appropriate defense in the related case where a battered woman kills her batterer while he is sleeping.) Maybe this fits the literal language of the duress defense: "the defendant engaged in the proscribed conduct because he was coerced to do so by the use or threatened imminent use of unlawful physical force upon him or a third person, which  force  or  threatened force  a  person of reasonable firmness in his situation would have been unable to resist." The answer would depend on what "coerced to do so" means. Certainly Bad Guy is not trying to get Good Guy to kill Innocent Shield; Bad Guy is using Innocent Shield to prevent Good Guy from shooting at Bad Guy; so a duress defense only works if we imagine that it includes unintended coercion.

Another possibility would be the defense of necessity. NY statutory law does not expressly recognize the defense of necessity, but it is encompassed within the general provision recognizing justification defenses. However, that provision by its terms excludes those defenses relating to the use of physical force, so, in New York, at least, necessity is unavailable. This reasoning also suggests that a duress defense would be unavailable. The legislature specifically considered the use of force in self-defense and concluded in Sec. 35.15 that it should only be permitted against the attacker, not against innocent third parties. Given the canon that the specific supersedes the general, it would be incongruous to say that nonetheless Good Guy can make out a defense of duress.

Thus, while recognizing that I'm not an expert in criminal law, I conclude that NY law--and the law of other states to the extent that it is similar--would not provide for a valid defense for Good Guy's foreseeable killing of Innocent Shield in my hypothetical example. Is that result normatively justified?

I think the answer is probably yes, for two reasons. First, on utilitarian grounds, it's worse to kill two people than one (even if one of the two is a criminal).

Second (and more importantly for me), on deontological grounds, it could be thought impermissible to deliberately act (as opposed to failing to act) in a way that causes severe harm to another, even if doing so avoids an equally severe harm. That is why many deontologists think it impermissible to switch the trolley from one track to another, even if they thereby avert a greater harm. Whether one agrees with that conclusion, even as a deontologist, depends on how seriously one takes the doctrine of double effect. Here, the killing of Innocent Shield is not the intended consequence of the act, just the regrettable side effect. Good Guy, in this view, is not using Innocent Shield in the way that the "fat man" is used in a variant on the trolley problem that nearly all deontologists find objectionable. Therefore, under the double effect doctrine, Good Guy acts permissibly if the incidental harm to Innocent Shield is proportionate to the harm averted. Double effect, in moral theory, as in IHL, requires both that the harm to innocents be collateral and proportionate. If you find this brief discussion of "trolleyology" too brief to get a handle on it, you might want to check out my earlier post on the subject.

What's notable here is that New York's criminal law does not appear to permit the foreseeable but unintended killing of innocents even when that killing is proportional. So if instead of threatening one person, Bad Guy were threatening two, or five, or a hundred, so long as the only way for one of those two, or five, or a hundred to disable Bad Guy is to shoot through Innocent Shield, as I read the criminal law, that would still be impermissible, even though it would be permissible for some deontologists under the double effect doctrine and permissible for utilitarians on the ground that it would save more lives. Yet domestic criminal law appears to categorically forbid the collateral killing of human shields. With respect to collateral harm to innocents, domestic criminal law is much more demanding of those who would use force in personal self-defense than IHL is of nations using force in war.

To be sure, in the domestic case Good Guy (or the two, five, or a hundred good guys in the variants) could still go ahead and shoot, hoping that a prosecutor will exercise her discretion not to bring charges (or to reduce the charges), that a grand jury will refuse to indict, or that a jury will nullify. But then, there are also mechanisms by which IHL is under-enforced. For many people who have committed war crimes, the de facto punishment amounts to no more than a foreign travel ban, because they remain powerful in their home countries.

If one thinks that the domestic law treatment of human shields is appropriate, then one will be tempted to say that the reform proposals to loosen the proportionality requirement in the face of human shields should be rejected. IHL already licenses more force against innocents than domestic criminal law, after all. But even if one thinks that the domestic law treatment of human shields (as I have described it) is too tough on the person placed in the difficult situation of needing to (regrettably and collaterally) take an innocent life to save his own, then at most one will end up concluding that the existing IHL norm allowing proportionate collateral harm to innocents is appropriate, but one will need a further argument for loosening that norm based on the enemy's use of involuntary human shields. Such a further argument would have to explain how and why nations should be given greater leeway to inflict collateral harm against human shields than individuals should be given. I suppose such an argument could be made, but I haven't seen it.


David Ricardo said...

I would argue that the basic premise of Mr. Dorf’s commentary is not analogous to the situation with respect to Israel and Gaza. Here is the situation set up by Mr. Dorf.

“But realistic or not, here is what I have in mind: Bad Guy, with the intent to kill Good Guy, has a gun pointed at Good Guy, who also has a gun, but Bad Guy is holding Innocent Shield in front of him, so that the only way that Good Guy can shoot Bad Guy before Bad Guy shoots Good Guy (who cannot safely retreat) is by shooting in a way that will foreseeably (albeit regrettably) harm or kill not just Bad Guy but also Innocent Shield. Is Good Guy permitted to shoot?”

Notice that this envisions a standoff, similar to what one would view in a classic western or crime themed movie. But this standoff with Bad Guy threatening Good Guy is not what has happened in the situation with Israel and Gaza. Hamas is not pointing unfired missiles at Israel and Israel is not taking pre-emptive strikes at Hamas in fear that the missiles will be fired.

Hamas is firing thousands of missiles at Israel with the sole intention of wounding and killing as many civilians as possible. So in the actual situation Bad Guy is not just pointing a gun at Good Guy, Bad Guy is firing with an unlimited magazine at Good Guy and trying to kill not only Good Guy but all of his friends, family and fellow citizens. This changes things, and the horrific fact that Good Guy must harm Innocent Shield to protect himself and his extended community against the actual, not potential but actual attack does not lessen the moral and legal right of Good Guy to do so.

Almost all observers and commentators of the situation in Gaza are ignoring the fact of the Hamas firing missiles because the missiles have either been ineffective or defeated by Israel’s Iron Drone defenses. But the success of Israel does not change the fact that Bad Guy is not simply threatening harm, but actually attacking with weapons that will do massive harm and this changes the situation to such a degree that the arguments that Mr. Dorf makes may well be correct but irrelevant to the actual situation on the ground in Gaza.

Must Israel have to wait until thousands are killed to gain the legal/moral authority to attack those who are not just threatening harm but are actually attacking? No, not now, not ever. Never again.

pvine said...

Domestically, in California at least, Good Guy would not be liable for any crime by killing/wounding Bad Guy (or the innocent hostage/human shield being held by Bad Guy). Rather, Bad Guy is the proximate cause of the injuuries to/death of the innocent hostage/human shield and, as such, would be criminally liable for the wounding or killing of the innocent hostage/human shield by Good Guy.

California uses the terms "provocative act" murder and "implied malice" murder in describing Bad Guy's criminal liability for proximately causing the the harm to the innocent hostage/human shield inflicted by Good Guy. (See, People v. Gardner (1995) 37 Cal.App.4th 473)

So what is the proximate cause of the deaths of "civilians" in Gaza? Hamas' intentional/malicious act of putting them in/allowing them to be/forcing them into harm's way with knowledge of Israel's intent?

What was the proximate cause of the deaths of hundreds of thousands of civilians during WWII when America dropped the A-Bombs and the Brits firebombed Dresden? Who initiated (and continued) those conflicts with knowledge that America/England would strike back with force designed to annihilate as many Nazis and Japs as possible, and with knowledge that, in defending its people, America/England would most likely kill and wound hundreds of thousands of civilians?

It's pretty clear to me who are the Good Guys and the Bad Guys in the Israeli-Hamas conflict. And who is solely responsible for the harm to "civilians" on either side of the border.

el roam said...

Thanks for an interesting post . The issue of course , is too complicated to be treated as a whole here . But I must notice one great flaw in that analysis of comparing the criminal law and war law .

Generally speaking , in criminal law , one can't assert the cause of any justification , if the alleged offender , has put himself in advance into the criminal situation .

By contrast , a war , is usually conducted in pre- meditative manner , so : you are never taken by surprise !! you don't find yourself , cognitively , all of a sudden in a situation of war .

In such : one must conclude – the main question or issue , in your analogy of bad guys or good guys , is not only whether there is justification for the shooting of the good guy on bad guy and his innocent shield , but rather :

Has the good guy been forced to that situation at first place ? was he taken by surprise ? or intentionally driven himself to it ?? Without that Q, one can't at first place, analyses correctly that analogy with the lawful conduct of wars.


pvine said...

Prof. Dorf,

If you have not already done so, take a look at Fischer, Douglas H. "Human Shields, Homicides, and House Fires: How a Domestic Law Analogy Can Guide International Law Regarding Human Shield Tactics In Armed Conflict." American University Law Review 57, no. 2 (December 2007): 479-521.

See, also, Kris Borer, "The Human Body Sword," Libertarian Papers 2, 20 (2010). ONLINE AT:

Greg said...

Ultimately, it seems to me that what this really comes down to is "in 1945, was the U.S. morally obligated to invade Japan instead of dropping the atomic bomb?"

Let's assume for the moment that these are combatants that each have a legitimate state interest with the other that cannot be resolved without the use of force. I think this adequately describes at least the combatants view of the situation in Gaza.

Based on that view, once war is initiated, "proportional" civilian casualties becomes a very fuzzy concept. One very big problem I have with this is that whether a person counts as a civilian or a combatant isn't a static thing. Depending on the choice of military action, more people on the other side may choose to take up arms, as such becoming combatants.

Thus, if significantly more PEOPLE die as a result of a military decision, but all of those people who die happen to fit the definition of combatant, is that automatically the morally superior decision? (thus requiring the US to invade Japan.)

We can talk about specific operations and if those specific targets represent a significant enough lapse of judgement so as to constitute a war crime (read: bombing a known UN shelter), but in general human shields aren't really that different from residences that happen to be adjacent to the factories because then the commute is shorter. War is hell. People die. Some of those people are children.

I think it's silly to ask if a decision killed a proportional amount of civilians without asking what the alternatives were and what their consequences would be. Of course doing nothing is always an option, but so is fire-bombing all of Gaza.

While some particular airstrikes may be ill-conceived, at a high level targeted airstrikes are preferable to an all-out ground assault, even if a higher percentage of the deaths in a ground assault would be combatants. Unfortunately, Israel is now engaged in both, making even a short-term peace that much harder to achieve.

I guess my real thought is that while the number of civilian casualties X may not change based on whether or not civilians are being used as a human shield... 1.) I feel X is a lot bigger than many people think it is, and 2.) X should be dependent on a lot more factors than simply how many combatants will be killed.

From a slightly different perspective, I don't see body count as being what would make Israel subject to war crimes. Things like actively restricting the ability of civilians to leave the combat zone (i.e. all of Gaza) would seem far more likely to make them at least morally culpable for civilian deaths.

Michael C. Dorf said...

Let me preface this reply by noting first, my thanks to readers for keeping comments on topic, as requested, and second, that I won't respond to everything.

1) David Ricardo: I don't think that the domestic law analysis changes if we assume that Bad Guy has already fired his gun and the question is whether Good Guy can return the fire.

2) pvine: I don't think your example makes the point. I looked at the case you cited and all it says is that the initiator of the violence can be held criminally responsible for the death; it does not say that someone else cannot ALSO be held criminally responsible. In my hypothetical example, Bad Guy, if he survives, could be held criminally liable for felony murder of Innocent Shield and Good Guy could also be held criminally liable for reckless murder of Innocent Shield. Maybe California law is different but I doubt it. E.g., in every state, the fact that a hit man can be convicted of murder (and is one proximate cause of the murder) does not mean that the person who hired the hit man cannot also be prosecuted for the same murder. And this is the point of my whole inquiry in IHL: Does the wrong of the shielding party excuse the wrong of the attacker, in whole or in part?

3) el roam: I agree--although at some point if we broaden our inquiry too much, we end up blurring the lines between jus ad bellum and jus in bello.

4) pvine: Thanks! I saw those sources in my research but will go back and take a closer look.

5) Greg: You are right to note that I never say how large X is, and IHL is quite vague on this point. Saying that X civilian casualties is proportionate to the achievement of some military objective Y requires a kaleidoscopic judgment encompassing all sorts of questions, including some, like those raised by el roam, that seem to be more appropriate as questions of large-scale strategy.

pvine said...

Prof. Dorf,

Your hitman/person who hired hitman scenario is simply an example of two Bad Guys, each of whom bears criminal liability for a murder.

In the Innocent Shield hypo there is only one Bad Guy and one Good Guy -- the later having been compelled by the criminal conduct of the Bad Guy to take the life of the Innocent Shield. Or, stated another way, but for the criminal conduct of the Bad Guy the Innocent Shield would be alive.

From my perspective, just like during WWII, there is one Bad Guy and one Good Guy in the Israeli-Hamas war. In 1945 it was Nazi Bad Guys who were committed to world domination and the slaughter of, among others, millions upon millions of innocent Jews.

Today's Bad Guy is Hamas whose charter calls for the annihilation of the Jewish State -- the only Good Guy in this conflict -- at any cost, including using Innocent Shields.

When dealing with that type of threat to your existence -- as the Good Guy is in your original hypo, as the Allies were during WWII, and as Israel is doing today in a very restrained manner given its real military might -- concepts regarding proportional force are misnomers and there is only one Good Guy who bears no responsibility for civilians injuries and deaths that, but for the criminal conduct of the sole Bad Guy, would never have taken place.

However, unlike your initial kill-or-be-killed hypo there is a solution to the Israeli-Hamas-Innocent Shield condudrum. The Innocent Shields, to the extent they exist, to the extent that they are a majority, and to the extent that Gaza is a democratic state, must do what the innocent German people should have done to Hitler.

Do I think that will happen? Not a chance in hell. Rather, absent a retreat by the Bad Guy and their forgoing the use of Innocent Shields for political and military objectives, the "final solution" this time around is in the hands of the Good Guy.

As Greg so aptly said: War is hell. So think twice before you go down that path.

Michael C. Dorf said...

pvine: To be clear, I gave the hit man example only to respond to the suggestion in your initial comment that if X is the proximate cause of the murder of A, then Y cannot also be the proximate cause. That is false when X and Y are both bad guys and, per my analysis of NY law, can also be false when X is the aggressor and Y is not.

As to your broader point, it echoes the Vanderbilt J Trans'l Law Note that I discussed: Where X uses human shields, both the author of the Note and you would entirely relieve the responding country from the proportionality norm. That would be a fairly dramatic change in international law. By contrast, the proposal of Rubinstein and Roznai can be understood as an interpretation of the existing IHL norm.

pvine said...

At the risk of going too far off topic, I just want to be clear: I don't believe that the responding country be "enitrely" relieved from the proportionality norm. But I do believe that the determination of what is a lawful proportional response when terrorists use human shields as part of their battle tactics depends upon many factors including, but not limited to, whether or not the responding country can reasonably carry out its lawful military mission in a manner that will spare the lives and limbs of truly innocent human shields while, at the same time, not unreasonably placing its own innocent people at risk of death or injury.

There is balancing involved in this difficult determination. And it is easy for the world, including the United States, to second-guess this balancing especially when it is not their citizens lives and their country's survival that is being placed in harms way by a fanatical, terrorist regime.

Shak Olreal said...

For what it's worth, I think that's probably wrong even on its own terms. Even if foreseeably killing unlimited numbers of human shields were lawful under IHL, many countries would refrain from doing so out of moral and/or public relations considersations, and so there would remain an incentive for the other side in a conflict to use human
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Bob Hockett said...

I'll have to defer to Mike, as well as to others writing or cited here who (like Mike) have spent a bit of time with IHL and state criminal law, where the legality of Good Guy's innocents-harming self-defense is concerned. I feel somewhat more confidence, however, in saying that both IHL and the criminal law then strike me, insofar as they are correctly interpreted by Mike and others here, as somewhat surprising. For in such case they would appear to require supererogatory behavior on the part of Good Guy. And such requirements seem to be more rare in the law even than they are in morality.

I hasten to add that, in the spirit of Mike's request, I am hewing closely to the hypothetical here. When I broaden the frame to include what strike me as all morally relevant characteristics of the current conflict, I find it hard not to think along the lines that pvine traces over the course of his four comments.

Thanks for the food for thought!

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