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* Professor, University of Illinois at Chicago, Department of Criminal
Justice. (Ph.d., Northwestern; J.D., American; LL.M., Harvard). A portion of
this research was undertaken during the author's service as "of counsel" for
Bosnia and Hercegovina in its suit against "Yugoslavia (Serbia and
Montenegro)" in the International Court of Justice. This article is dedicated
with lasting love and devotion to Lidia Janus (June 9, 1958 - January 24,
1991) who lived with humanism, integrity, and passion and who longed for a
Poland and a Europe free of perversity, prejudice and hate. Lidia continues
to inspire us in death as she did in life. We will never forget . . .
1 . See Matthew Lippman, Nuremberg and American Justice, 5 NOTRE DAME J.L.
ETHICS & PUB. POL'Y 951 (1991); Matthew Lippman, Nuremberg: Forty Five Years
Later, 7 CONN. J. INT'L L. 1 (1991).
2 . See Matthew Lippman, The Other Nuremberg: American Prosecutions of Nazi
War Criminals in Occupied Germany, 3 IND. INT'L & COMP. L. REV. 1 (1992). See
also Matthew Lippman, The Nazi Doctors Trial And The International
Prohibition On Medical Involvement In Torture, 15 LOY. L.A. INT'L & COMP.
L.J. 395 (1993); Matthew Lippman, They Shoot Lawyers Don't They?: Law In The
Third Reich And The Global Threat To The Independence Of The Judiciary, 23
CAL. W. INT'L L. J. 257 (1993).
3 . See IV TRIALS OF WAR CRIMINALS BEFORE THE NUERNBERG MILITARY TRIBUNALS
UNDER CONTROL COUNCIL LAW No. 10 411 (1950)[hereinafter EINSATZGRUPPEN
JUDGMENT]; XI TRIALS OF WAR CRIMINALS BEFORE THE NUERNBERG MILITARY TRIBUNALS
UNDER CONTROL COUNCIL LAW No. 10 462 (1950) [hereinafter HIGH COMMAND
JUDGMENT]; XI TRIALS OF WAR CRIMINALS BEFORE THE NUERNBERG MILITARY TRIBUNALS
UNDER CONTROL COUNCIL LAW No. 10 1230 (1950) [hereinafter HOSTAGE JUDGMENT].
4 . See generally Matthew Lippman, The Denaturalization Of Nazi War Criminals
In The United States: Is Justice Being Served? 7 HOUS. J. INT'L L. 169
(1985); Matthew Lippman, The Drafting of the 1948 Convention on the
Prevention and Punishment of the Crime of Genocide, 3 B.U. L.J. 1 (1994);
Matthew Lippman, The Trial Of Adolf Eichmann And The Protection Of Universal
Human Rights Under International Law, 5 HOUS J. INT'L L. 1 (1982).
5 . See ADOLF HITLER, MEIN KAMPF (Ralph Manheim trans., Houghton Miffflin,
1975) (1925).
6 . See id. at 611.
7 . See id. at 3.
8 . See id. at 642-43.
9 . See id. at 662, 666.
10 . See id. at 327, 679.
11 . See id. at 623.
12 . Id. at 654 (emphasis omitted). See also id. at 632.
13 . See id. at 644-45, 652.
14 . See id. at 138.
15 . See id. at 643, 646.
16 . Id. at 646.
17 . Id. at 652 (emphasis omitted).
18 . Id.
19 . Id.
Just as our ancestors did not receive the soil on which we live today as a
gift from Heaven, but had to fight for it at the risk of their lives, in the
future no folkish grace will win soil for us and hence life for our people,
but only the might of a victorious sword.
Id. at 653.
20 . Id. at 653 (emphasis omitted).
21 . Id. at 138.
22 . Id. at 281.
23 . Id. at 294-95. "If we were to divide mankind into three groups, the
founders of culture, the bearers of culture, the destroyers of culture, only
the Aryan could be considered as the representative of the first group." Id.
at 290.
24 . Id. at 296.
25 . Id. at 302.
26 . Id. at 402 (emphasis omitted).
27 . Treaty Of Peace With Germany (Concluded at Versailles, June 28, 1919) 13
A.J.I.L. 151 (Supp. 1919) (hereinafter Treaty of Versailles).
28 . See id. arts. 159-202.
29 . See id. arts. 203-10.
30 . Opening Statement of the Prosecution, TRIALS OF WAR CRIMINALS BEFORE THE
NUERNBERG MILITARY TRIBUNALS UNDER CONTROL COUNCIL LAW NO. 10 61, 65 (1951)
[hereinafter HIGH COMMAND MATERIALS].
31 . Id. at 66. The phrase "'stabbed in the back'" was invoked by Field
Marshal von Hindenburg in an appearance before a legislative committee of
inquiry in November 1919. Id.
32 . Interoffice Memorandum Of Reich Defense Ministry, 18 January 1927,
Concerning Illegality Of Mobilization Measures, supra note 30, at 427, 428
(emphasis omitted).
33 . See Opening Statement of the Prosecution, id. at 70-71.
34 . Id. at 72.
35 . Extracts From "Voelkischer Beobachter" of 2 and 6 February 1933,
Concerning Relations Between The Armed Forces And Hitler, supra note 30, at
468, 469.
36 . Id. at 78. "I take this holy oath before God, that I will render
unconditional obedience to the Fuehrer of the German Reich and of the German
people, Adolf Hitler, and as a brave soldier will be prepared at any time to
sacrifice my life for this oath." Extract From "Voelkischer Beobachter" of 3
August 1934, Reporting The Taking Of Oath Of Allegiance To Hitler By Armed
Forces, id. at 473.
37 . Quoted in Opening Statement of the Prosecution, id. at 77.
38 . Id. at 74.
39 . Extracts From Article By Reich Minister General Von Blomberg On "The
German Conscription," Published In The "Voelkischer Beobachter," 20 March
1935, id. at 473-74.
40 . Extracts From "The Fight Of The Navy Against Versailles, 1919-1935
Dealing Principally With Concealed Rearmament, id. at 432, 455. A secret
history of the German Navy noted that "[o]nly when the Fuehrer had created
the . . . condition for an effective rearmament, by the coordination of the
whole nation and in the fusion of the political, financial, and intellectual
forces, could the work of the soldier find its fulfillment." Id. at 433.
41 . Opening Statement of the Prosecution, supra note 30, at 76-77. See
Treaty of Versailles, supra note 27, at arts. 42-43. "In case Germany
violates in any manner whatever the provisions of Articles 42 and 43, she
shall be regarded as committing a hostile act against the Powers signatory of
the present Treaty and as calculated to disturb the peace of the world." Id.
at art. 44. See also Directive 2 May 1935 Concerning Preparation For The
Reoccupation Of The Rhineland, supra note 30, at 474; Extracts From Hitler's
Reichstag Speech, 21 May 1935, Published In "Voelkischer Beobachter," 22 May
1935, id. at 476; Order, 2 March 1936, For The Reoccupation Of The Rhineland,
id. at 484.
On Hitler's birthday, April 20, 1936, he promoted Blomberg to field marshal,
the first German to be appointed to this rank since World War I. Fritsch and
Goering were made full generals and Raeder was appointed to Generaladmiral.
See Extract From Hitler's Speech To Military Leaders On His Birthday, 20
April 1936; Published in "Voelkischer Beobachter," 21 April 1926, id. at 487.
42 . II NAZISM 1919-1945 A HISTORY IN DOCUMENTS AND EYEWITNESS ACCOUNTS
637-638 (J. Noakes & G. Pridham, eds., 1988).
43 . Extracts From Speeches By General Liebmann And Von Blomberg, 15 October
1935, Commemorating The 125th Anniversary Of The War Academy; Published In
"Berliner Boersenzeitung," 16 October 1935, supra note 30, at 477, 478.
44 . Extracts From Speech By The Chief Of The General Staff, Lieutenant
General Beck, 15 October 1935, Commemorating The 125th Anniversary Of The War
Academy; Published In "Berliner Boersenzeitung," 16 October 1935, id. at 483,
484.
45 . Quoted in Noakes & Pridham, supra note 42, at 641.
46 . Id. at 642.
47 . Quoted in id. at 643-44. See also Draft Curriculum for the Academy of
Naval Administration of 1938, reprinted in id. at 644.
48 . See Letter From Von Blomberg To Commanders In Chief Of Army, Navy, And
Air Force, 24 June 1937, Inclosing A Directive for The Unified Preparation
For War By The Armed Forces, supra note 30, at 488.
49 . Notes On Hitler Conference Of 5 November 1937, id. at 505, 506.
50 . Id. at 512.
51 . Opening Statement of the Prosecution, supra at note 30, 80-81.
52 . Id. at 82.
53 . Extract From "Voelkischer Beobachter," 6 February 1938, On Hitler Taking
Over Command Of The German Armed Forces, id. at 516-17. The remainder of the
order read as follows:
The former Chief of the Armed Forces Office will be at the head of the staff
of the High Command of the Armed Forces and will be known as 'Chief of the
High Command of the Armed Forces.' He will be equal in rank with the Reich
Ministers.
The High Command of the Armed Forces assumes at the same time the activities
of the Reich War Ministry; the Chief of the High Command of the Armed Forces
will exercise all functions of the former Reich War Minister under my
authority.
Id.
54 . Opening Statement of the Prosecution, id. at 83-84.
55 . HIGH COMMAND JUDGMENT, supra note 3, at 501-02.
56 . Id. at 503.
57 . Id.
58 . Opening Statement of the Prosecution, supra note 30, at 82. The
officer's Corps opposed the appointment of Reichenau as Commander in Chief of
the Army. Hitler compromised and appointed Lieutenant General von
Brauchitsch. Von Brauchitsch, however, lost the respect of his peers when he
agreed to replace the martyred von Fritsch. Goering gained von Brauchitsch's
gratitude by intervening to secure von Fritsch a divorce so as to permit him
to remarry. Von Brauchitsch reciprocated by agreeing to accept a large number
of modifications in the army leadership. Although promoted, von Brautchitsch
was outranked and overshadowed by Goering who had been promoted to field
marshall. Id.
59 . See XI TRIALS OF WAR CRIMINALS BEFORE THE NUERNBERG MILITARY TRIBUNALS
UNDER CONTROL COUNCIL LAW No. 10 793-95 (1950) [hereinafter HOSTAGE
MATERIALS]. The largest field formation in the German Army was known as the
"army group" which designated a headquarters controlling two or more armies.
Army groups were commanded by either a field marshal or a Generaloberster,
ranks which were equivalent to a five-star and four-star general
respectively. Below the army group, in descending order, were the corps, the
division and smaller units such as regiments, battalions and companies. There
were several types of divisions - infantry, armored (Panzer) and motorized
(Panzer Grenadier). In southeastern Europe mountain divisions also were
formed. See id.
The field forces of the German Army were nominally under the OKH, but
regularly received direction from the OKW. This frequently was the case in
the occupied territories. In these territories, the Germans often appointed a
senior "armed forces commander" (Wehrmachtsbefehlshaber) to whom the heads of
the army, navy and air force were responsible. The administration of the
region was customarily entrusted to an army general designated as "military
commander" (Militaerbefehlshaber). The latter was responsible for security
and order. See id. at 795-96.
The Einsatzgruppen were formed in the spring of 1941 as part of Heinrich
Himmler's the security apparatus. These squads functioned in the rear
operational areas and were charged with exterminating political
"undesirables" and opponents of the Nazi regime. See IV Trials Of War
Criminals Before The Nuernberg Military Tribunals Under Control Council Law
No. 10 35-38 (1950) [hereinafter EINSATZGRUPPEN MATERIALS].
60 . For a number of abortive attempts to assassinate and overthrow Hitler,
see MATTHEW COOPER, THE GERMAN ARMY 1933-1945 532 (1978).
61 . Id. at 534-36.
62 . See "Schackling Order," reprinted in id. at 542.
63 . Id. at 543. On April 18, Hitler declared, "'[i]f the German people loses
the war, it will have proved itself unworthy of me.'" Id.
64 . Id. at 554-556.
65 . See id. at 546.
66 . See CHRISTOPHER R. BROWNING, ORDINARY MEN RESERVE POLICE BATTALION 101
AND THE FINAL SOLUTION IN POLAND XV, XVI (1992).
67 . OMER BARTOV, HITLER'S ARMY SOLDIERS, NAZIS AND WAR IN THE THIRD REICH
28, 61 (1991).
68 . Id. at 71-72.
69 . Id. at 70. The army assimilated the Nazi ideology "with all its
social-darwinist, nihilist, expansionist, anti-Bolshevik, and racist
attributes." Id. "The army did not simply pretend not to notice the criminal
actions of the regime, it positively ordered its own troops to carry them
out, and was distressed when breaches of discipline prevented their more
efficient execution." Id.
70 . Id. at 152.
71 . Id.
72 . BROWNING, supra note 66, at 142.
73 . Id. at 47-48.
74 . Id. at 71-72.
75 . Id. at 73.
76 . See Shelford Bidwell, Kesselring, in HITLER'S GENERALS 265, 276
(Correlli Barnett ed. 1989). "If the mark of an outstanding man is that he
can cope with novel problems, whether of war, management or politics, without
any previous experience or special education, by using sheer intellect, then
Kesselring was such a man . . . ." Id. at 276.
77 . The Trial Of Albert Kesselring (Brit. Milit Ct., Venice, Italy, 17
February-6th May, 1947), UNITED NATIONS WAR CRIMES COMMISSION, VIII LAW
REPORTS OF TRIALS OF WAR CRIMINALS 9 (1949) [hereinafter KESSELRING CASE].
78 . Id.
79 . See Trial Of General Von Mackensen And General Maelzer (Brit Milit. Ct.,
Rome, Italy, 18th-30th November, 1945), UNITED NATIONS WAR CRIMES COMMISSION,
VIII LAW REPORTS OF TRIALS OF WAR CRIMINALS 1 (1949). On June 17th, 1944,
Kesselring issued the first of several orders on partisan warfare. The
directive urged that the fight should be carried out
with all means at our disposal and with the utmost severity. I will protect
any commander who exceeds our usual restraint in the . . . severity of the
means he adopts . . . a mistake in the choice of the means to achieve is
always better than failure to act or neglect . . . partisans must be attacked
and destroyed.
KESSELRING CASE, supra note 77, at 10. Over a thousand Italians were
arbitrarily executed by Kesselring's troops. Id. at 11.
80 . See KESSELRING CASE, supra note 77, at 12. Bidwell, supra note 76, at
287. Bidwell typifies the tendency to minimize the War Crimes committed by
the German military. He notes that Kesselring "was by nature genial. The
troops nicknamed him 'Smiling Albert,' and he can be seen in his photographs
always wearing a cheerful grin." Id.
81 . See Lippman, Nuremberg: Forty Five Years Later, supra note 1, at 7-12
(1991).
82 . See Case Of Lieutenants Dithmar And Boldt (RGSt July 16, 1921)
(Germany), reprinted in 16 A.J.I.L. 708, 721 (1922).
Any violation of the law of nations in warfare is . . . a punishable offence,
so far as . . . a penalty is attached to the deed. The killing of enemies in
war is in accordance with the will of the State that makes war . . . only in
so far as such killing is in accordance with the conditions and limitations
imposed by the law of nations. The fact that his deed is a violation of
international law must be well-known to the doer, apart from acts of
carelessness, in which careless ignorance is a sufficient excuse . . . .
Id.
83 . Declaration on German Atrocities (October 30, 1943) VI DOCUMENTS ON
AMERICAN FOREIGN RELATIONS (July 1943-June 1944) 231, 232 (1945).
84 . Id.
85 . XXII TRIAL OF THE MAJOR WAR CRIMINALS BEFORE THE INTERNATIONAL MILITARY
TRIBUNALS 534-89 (1948)(Judgment). The five military officials were Goering,
Commander in Chief of the Luftwaffe, id. at 524, 527; Keitel, Chief of the
High Command of the Armed Forces, id. at 533, 536; Donitz, Commander in Chief
of the German Navy, id. at 556, 561; Raeder, Chief of Naval Command until
succeeded by Donitz in 1943, id. at 561, 563; and Jodl, Chief of the
Operations Staff of the High Command of the Armed Forces under Keitel, id. at
568, 571. All five the major militarists also were convicted on the
aggressive war charge. See id.
86 . Id. at 527.
87 . Id. at 535.
88 . Id. at 522-23.
89 . The United States filed twelve major indictments. See Matthew Lippman,
The Other Nuremberg: American Prosecutions of Nazi War Criminals in Occupied
Germany, supra note 2.
90 . PUNISHMENT OF PERSONS GUILTY OF WAR CRIMES, CRIMES AGAINST PEACE AND
AGAINST HUMANITY, CONTROL COUNCIL LAW No. 10 (December 20, 1945), reprinted in
 VI TRIALS OF WAR CRIMINALS BEFORE THE NUERNBERG MILITARY TRIBUNALS UNDER
CONTROL COUNCIL LAW NO. 10 XVIII (1952).
91 . Id. art. II, para. (1)(2).
1. Each of the following acts is recognized as a crime:
(a) Crimes against Peace. Initiation of invasions of other countries and wars
of aggression in violation of international laws and treaties, including but
not limited to planning, preparation, initiation or waging a war of
aggression, or a war of violation of international treaties, agreements or
assurances, or participation in a common plan or conspiracy for the
accomplishment of any of the foregoing.
(b) War Crimes. Atrocities or offenses against persons or property
constituting violations of the laws or customs of war, including but not
limited to, murder, ill treatment or deportation to slave labor or for any
other purpose, of civilian population from occupied territory, murder or ill
treatment of prisoners of war or persons on the seas, killing of hostages,
plunder of public or private property, wanton destruction of cities, towns or
villages, or devastation not justified by military necessity.
(c) Crimes against humanity. Atrocities and offenses, including but not
limited to murder, extermination, enslavement, deportation, imprisonment,
torture, rape, or other inhumane acts committed against any civilian
population, or persecutions on political, racial or religious grounds whether
or not in violation of the domestic laws of the country where perpetrated.
(d) Membership in categories of a criminal group or organization declared
criminal by the International Military Tribunal.
Id. art. II para. (1)(a)-(d).
92 . Id. art. II, para 3. "Such punishment may consist of one or more of the
following . . . ." Id.
93 . Id. art. II, para 4(a). "The official position of any person, whether as
Head of State or as a responsible official in a Government Department, does
not free him from responsibility for a crime or entitle him to mitigation of
punishment." Id.
94 . See art. II, para. 4(b). Superior orders may be recognized in mitigation
of punishment. Id.
95 . Id. art. II, para. 5.
96 . Id. arts. III-IV. See also ORGANIZATION AND POWERS OF CERTAIN MILITARY
TRIBUNALS, ORDINANCE NO. 7 (October 18, 1946) reprinted in IV TRIALS OF WAR
CRIMINALS BEFORE THE NUERNBERG MILITARY TRIBUNALS UNDER CONTROL COUNCIL LAW
No. 10 XXXIII (1952), amended by ORDINANCE No. 11 reprinted in id. at XXIX
(establishing the composition and procedure of United States tribunals).
97 . Keitel, Order Concerning Anti-Band Warfare, 16 December 1942; Letter Of
Transmittal And Distribution List, 29 December 1942, supra note 30, at 1166,
1168.
98 . Letter Of Transmittal And "Reichenau Order", Of 10 October 1941,
Distributed by XXVIII Army Corps Of The 18th Army, Commanded By Defendant Von
Kuechler, id. at 1211, 1212.
99 . Id.
100 . Opening Statement of the Prosecution, Id. at 113. The Commando Order,
which had been prepared by defendants Walter Warlimont Chief of the Armed
Forces Operations Staff and Rudolf Lehmann, Chief of the Legal Division of
the OKW, provided that:
For some time our enemies have been using in their warfare methods which are
outside the international Geneva Convention. Especially brutal and
treacherous is the behavior of the so-called commandos who, as is
established, are partially recruited even from ex-convicts in enemy
countries. Captured orders reveal that they are directed . . . to shackle
prisoners . . . orders have been found in which the killing of prisoners has
been required as a standard practice.
. . .
>From now on all enemies on so-called commando missions in Europe or Africa
challenged by German troops, even if they are to all appearances soldiers in
uniform or demolition troops, whether armed or unarmed, in battle or in
flight, are to be slaughtered to the last man . . . . Even if these
individuals, when found should apparently be prepared to give themselves up,
no pardon is to be granted them . . . .
If individual members of such commandos . . . fall into the hands of the
military forces by some other means, through the police in occupied
territories for instance, they are to be handed over immediately to the
Security Service. Any imprisonment under military guard . . . is strictly
prohibited, even if this is only intended for a short time.
Supra note 30 at 115.
The "Commando Order," 18 October 1942, signed by Hitler with a note by the
defendant Warlimont concerning distribution of order, XI Trials Of War
Criminals Before The Nuernberg Military Tribunals Under Control Council Law
No. 10 73-74 (1951) [hereinafter HIGH COMMAND MATERIALS II].
Captured American, British, French, Norwegian and Greek commandos were
executed pursuant to this order. Opening Statement of the Prosecution, supra
note 30, at 115-116. Russian soldiers who were separated from their units and
who were apprehended behind German lines in Russia also were executed. See
Letter From XXX Army Corps (Commanded By Defendant Von Salmuth) To
Subordinate Units, 7 August 1941, Transcribing Extracts From Army High
Command Regulation Concerning Treatment Of Enemy Civilians And Russian
Prisoners Of War, 25 July 1941, HIGH COMMAND MATERIALS II, supra note 100, at
66.
101 . See Reich Minister Dr. Goebbels, A Word On The Enemy Air Terror, HIGH
COMMAND MATERIALS II, supra note 100, at 166-169. The Reich claimed that the
pilots had been deprived of the protections customarily accorded to prisoners
of war. Walter Warlimont was primarily responsible for drafting the 1944
order which directed German officers to permit civilians to take punitive
action against Allied pilots.
You will take immediate steps to ensure . . . that soldiers do not oppose the
civilian population . . . by demanding that the enemy flyers be handed over .
. . as prisoners, and . . . thus ostensibly siding with, the enemy terror
flyers.
No fellow German can understand such an attitude on the part of our armed
forces. The inhabitants of the occupied territories, too, must not be
restrained from taking matters into their own hands because of their
justified indignation against the Anglo-American terror flyers, or from
giving other expressions of their justified resentment against captured
members of the enemy forces . . . .
Order By General Schmidt, 11 December 1944, Transmitting Order Of Chief OKW
Of 9 July 1944, Concerning Oral Instructions To Be Given To Soldiers Not To
Protect Enemy "Terror" Flyers From The German Populace, id. at 179, 180.
102 . Opening Statement of the Prosecution, supra note 30, at 123.
103 . Id. at 124.
104 . The Commissar Order With Distribution List, And Covering Letter By
General Von Brauchitsch, Commander In Chief Of The Army, 8 June 1941,
Containing Supplements To The Order, id. at 1055, 1056.
[I]t is wrong to treat such elements [commissars] with clemency and
consideration in accordance with international law. They are a menace to our
own safety and to the rapid pacification of the conquered territories.
[T]he originators of the Asiatic barbaric methods of fighting are the
political commissars. They must be dealt with promptly and with the utmost
severity.
Id. at 1056.
Commissars were identified by the fact that they displayed a red star with an
inwoven gold hammer and sickle on their sleeves. The Germans refused to
recognize the commissars as lawful combatants who were entitled to prisoner
of war status. Suspected commissars were to be brought before officer charged
with disciplinary power. After obtaining the concurrence of two other
officers that the detainee was a political commissar, the officer was obliged
to order the individual's summary execution. See Draft Of Commissar Order,
Undated, Prepared According To Directives Of 31 March 1941, And Comment By
Defendant Lehmann, 8 May 1941, Id. at 1060, 1061. The executions were to be
carried out in camps located in the rear of the front line in order to avoid
publicity. See Extract From Activity Report No. 2 Of Panzer Group 3,
January-July 1941, Concerning Special Treatment Of Commissars, id. at 1085.
105 . Opening Statement of the Prosecution, id. at 128.
106 . Id. at 129. See Extract From Operational Order No. 8, By Heydrich,
Chief Of The Security Police And SD, 17 July 1941, And Enclosures, On
Segregation And Treatment Of Certain Categories In PW Camps, supra note 100,
at 5-11; Letter Of 26 September 1941, From Heydrich's Office, Enclosing
Letter Of Transmittal, Signed By Defendant Reinecke, And Directives For The
Treatment Of Soviet Prisoners Of War, 8 September 1941, id. at 11-15.
107 . Opening Statement of the Prosecution, HIGH COMMAND MATERIALS, supra
note 30, at 130.
108 . Id. Reports often listed those prisoners who were murdered as having
been killed while attempting to escape. A September 14, 1941 report by one of
the divisions under the command of defendant Lieutenant General Karl Von
Roques recorded that, "'[n]umerous escapes of Russian prisoners of war from
rail transports have been reported. Guard Battalion 703 captured 13 and shot
them.'" Id. at 131.
Conditions in the prisoner of war camps were harsh and severe. See Excerpt
>From "Ten-Day Report," From Rear Area Army Group South (Commanded By The
Defendant Von Roques) To The High Command Of The Army, 20 December 1941,
Concerning PW Deaths In Transit Camps, And Remarks Of PW District Commander,
21 December 1941, On The Plan Concerning The Release Of Ukrainian Prisoners
Of War, HIGH COMMAND MATERIALS II, supra note 100, at 31. A December 21, 1941
report from a prisoner of war district under Roques' command estimated that
the persistence of existing mortality rates in four camps over the course of
the next year would result in the death of between
twenty-eight-to-eighty-seven percent of the prisoners. By 1944, nearly two of
the five million prisoners in camps under the control of OKH and the OKW had
died, not including those who had been summarily executed. See Opening
Statement of the Prosecution, supra note 30, at 132.
109 . Opening Statement of the Prosecution, supra note 30, at 118-119.
Individuals were prosecuted in the occupied territories and were not
subjected to deportation where "it appears probable that death sentences are
going to be passed against the offenders . . . and if the trial and the
execution of the death sentence can be carried out without delay." Id. at
119. See Night And Fog" Decree Of Hitler, Signed By Keitel, 7 December 1941,
Concerning Measures To Be Taken Against Persons Offering Resistance To German
Occupation, supra note 100, at 196.
110 . Keitel Letter Of 12 December 1941, Transmitting The First
Implementation Decree To The "Night And Fog" Decree, supra note 100, at 198.
The so-called "NN" prisoners were incarcerated in death camps such as Dachau
where they were starved, abused and tortured. Those acquitted as well as
those who had completed their sentence were turned over to the Gestapo and
frequently were subjected to additional ill-treatment and typically were
summarily shot. Opening Statement of the Prosecution, supra note 30, at 120.
In 1944, defendant Rudolf Lehmann, Ministerial Director in the OKW and Chief
of the Legal Division, received a communique informing him that due to the
large number of executions and cremations of "NN" prisoners that there were
doubts whether "'the separation of the ashes of the individual dead is
guaranteed.'"Id. at 121.
111 . Opening Statement of the Prosecution, supra note 30, at 134-35. The
Barbarossa Order had been drafted by defendants Walter Warlimont and Rudolf
Lehmann and distributed on May 15, 1941, five weeks prior to the Nazi
invasion of Russia. Id. See Army High Command Draft Of Barbarossa Order, May
1941, Addressed To Army And Army Group Commanders, id. at 1124.
112 . Extracts From Activity Report NO. 2 Of Panzer Group 3, January-July
1941, Concerning Treatment Of Commissars, Partisans, ETC. id. at 1132, 1133.
113 . Opening Statement of the Prosecution, id. at 136.
114 . Covering Letter From 18th Army, 28 September 1941, Transmitting Keitel
Order, 12 September 1941, Concerning Jews In The Occupied Territories, id. at
1210, 1211.
115 . Opening Statement of the Prosecution, Id. at 139-141. A typical report
was filed by the 454th Security Division from Kiev in October 1941.
The Jews of the city were ordered to present themselves at a certain place
and time for the purpose of numerical registration and housing in a camp.
About 34,000 reported, including women and children. After they had been made
to give up their clothing and valuables, all were killed; this took several
days.
Extract From Activity Report Of 454th Security Division For Period From 1-10
October 1941, id. at 1257, 1258.
An order from defendant, Lieutenant General Otto Woehler to his troops in the
southern Ukraine noted that "the Jews are trying to buy clothing and canned
food from the soldiers. I have ordered these creatures to be arrested. To sum
up - the Jews must disappear." Extract Of Teletype From Defendant Woehler To
Army Group Southern Ukraine, 31 May 1944, Concerning Treatment Of Jews, id.
at 1264.
116 . Extract From Report On Partisan Activities By The Commanding General Of
Security Troops And Commander Of Rear Area Army Group North, 1-15 June 1942,
Concerning The Shooting Of Gypsies, id. at 1192, 1193. See also Directive
>From 281st Security Division To Feldkommandatur 822, 24 March 1943,
Concerning The Handing Over Of Gypsies And Jews To The SD, id. at 1194, 1195.
117 . See Extracts From XXVIII Corps Activity Report And Correspondence For
Period 7-26 December 1941, Pertaining To Liquidation Of Insane At
Markarevskaaja Asylum, id. at 1196-1200. Ironically, German soldiers were
prohibited from taking photographs of exterminations or detailing the deaths
in letters. Defendant Woehler explained that such accounts "are looked upon
as undermining the decency and discipline in the armed forces . . . [and
that] [i]t is beneath the dignity of a German soldier to watch such incidents
out of curiosity." Copy Of Letter, 22 July 1941, From 11th Army, Signed In
Draft By Defendant Woehler, Concerning Photographs And Reports Of Executions,
id. at 1209.
118 . Opening Statement of the Prosecution, id. at 145.
119 . Id. at 147-149.
120 . Extracts from the Closing Statement of the Prosecution, supra note 100,
at 331, 351-352.
121 . Opening Statement of the Prosecution, supra note 30, at 145-46.
122 . Id. at 146.
123 . Id.
124 . Id. at 147.
125 . Id.
126 . See infra notes 485-514 and accompanying texts.
127 . HIGH COMMAND JUDGMENT, supra note 3, at 695-96. The disposition of the
defendants was as follows: Otto Schniewind acquitted; Hugo Sperrle,
acquitted; Wilhelm Von Leeb, three years imprisonment; Georg Karl
Friedrich-Wilhelm Von Kuechler, twenty years imprisonment; Hermann Hoth,
fifteen years imprisonment; Hans Reinhardt, fifteen years imprisonment; Hans
Von Salmuth, twenty years imprisonment; Karl Hollidt, five years
imprisonment; Hermann Reinecke, life imprisonment; Walter Warlimont, life
imprisonment; Otto Woehler, eight years imprisonment; Rudolf Lehmann, seven
years imprisonment. None of the defendants was convicted of Crimes against
Peace. Id. The members of the Tribunal were Judge John C. Young, formerly
Chief Justice of the Supreme Court of the State of Colorado; Judge Winfield
B. Hale, Judge of the Court of Appeals of the State of Tennessee; and Judge
Justin W. Harding, formerly District Judge of the First Division, Territory
of Alaska. HIGH COMMAND MATERIALS, supra note 30, at 8.
128 . HIGH COMMAND JUDGMENT, supra note 3, at 491.
129 . Id. at 489.
130 . Id. The Court noted that although Hitler possessed dictatorial control,
that he had to depend upon others to prepare, plan and wage his aggressive
wars.
Somewhere between the Dictator and Supreme Commander of the Military Forces
of the nation and the common soldier is the boundary between the criminal and
the excusable participation in the waging of an aggressive war by an
individual engaged in it. Control Council Law No. 10 does not definitely draw
such a line.
Id. at 486.
The Tribunal held that two elements were required to constitute criminal
liability for involvement in an aggressive war. First, actual knowledge that
an aggressive war is intended and that if launched that it will constitute an
aggressive war. In addition, the individual who possesses such knowledge must
be in a position to shape or influence the policy either by furthering or by
hindering or preventing the war effort. "If he . . . does the former, he
becomes criminally responsible; if he does the latter to the extent of his
ability, then his action shows the lack of criminal intent with respect to
such policy." Id. at 488. An individual at the policy-level who acquires
knowledge of the illegal nature of such conflicts following the initiation of
aggression also is liable to criminal punishment. Id. at 488-89.
The defendants claimed that the aggressive war charge was rendered a nullity
by the fact that the Soviet Union, one of the signatories of Control Council
Law No. 10, had initiated a war of aggression. However, "[u]nder general
principles of law, an accused dies not exculpate himself from a crime by
showing that another committed a similar crime, either before or after the
alleged commission of the crime by the accused." Id. at 482.
131 . Id. at 489.
132 . See id. at 491.
133 . Id. at 491-95.
134 . Id. at 495-96.
135 . Id. at 507-08. The Court observed that an order to violate
international common law is void and affords no protection to an individual
who acts pursuant to such a directive. It was observed that this is
consistent with the purpose of international law which is to direct the
actions of the citizen or subject. Id. at 508.
The Court conceded that those defendants who received criminal orders were
placed in a difficult position. However, servile compliance based upon a fear
of disadvantage or punishment does not constitute a justification. The
defense of coercion or necessity required a "showing of circumstances such
that a reasonable man would apprehend that he was in such imminent physical
peril as to deprive him of freedom to choose the right and refrain from the
wrong. No such situation has been shown in this case." Id. at 509.
136 . Id. at 510-11.
137 . Id. at 511.
Military commanders in the field with far reaching military responsibilities
cannot be charged under international law with criminal participation in
issuing orders which are not obviously criminal or which they are not shown
to have known to be criminal under international law . . . . He, [the field
commander], has the right to presume, in the absence of specific knowledge to
the contrary, that the legality of such orders has been properly determined
before their issuance. He cannot he held criminally responsible for a mere
error in judgment as to disputable legal questions.
It is therefore considered that to find a field commander criminally
responsible for the transmittal of such an order, he must have passed the
order to the chain of command and the order must be one that is criminal upon
its face, or one which he is shown to have known was criminal.
Id.
138 . Id. at 512.
139 . Id. at 513. A chief of staff in the German Army did not possess command
authority and an order affixed with his signature did not carry authority for
subordinates in the chain of command. A chief of staff customarily signed
directives for and by order of his commanding officer. Such orders were
presumed to express the desires of the commanding officer. Id. at 514.
140 . Id. at 515.
141 . Id.
142 . Id.
143 . Id. at 520.
144 . Id. at 520-21.
145 . Id. at 525. Innocent individuals were summarily executed under the
pretext that they were guerrillas who failed to comply with the requirements
of the humanitarian law of war. Id. at 531.
146 . Id. at 523-24. The Commando Order also was considered "criminal on its
face. It simply directed the slaughter of . . . troops." Id. at 527. The
Night And Fog Decree "was another criminal order from Hitler's brain." Id.
The "enforcement of this cruel and brutal order cost the lives of many
innocent people and untold suffering and misery to their loved ones." Id. at
528.
147 . Id. at 538-39.
148 . Id. at 539-41.
149 . Id. at 541.
150 . Id. at 543-44.
151 . Id. at 547.
152 . Id. at 547. "[S]ome 40,000 Jewish women and children were liquidated in
Riga which at that time was in the Commissariat Ostland, immediately to the
rear of the Army Group North." Id.
153 . Id. at 549.
154 . Id. at 549-50. For instance, in October 1939, Wilhem von Leeb,
Commander of Army Group North in the Russian campaign, wrote
Commander-in-Chief von Brauchitsch that Germany's planned invasion of France
likely would lead to protracted trench warfare. He also warned that Russia,
the United States and the British Commonwealth might align and assist the
French. Roughly three weeks later, von Leeb again wrote von Brauchitsch
urging Hitler to accept the partitions of Czechoslovakia and Poland. Id. at
549-51. Von Leeb predicted that this would result in the Fuehrer being
"'honored as a prince of peace, not only by the entire German people, but
assuredly also by large parts of the world as well.'" Id. at 551.
155 . Id. at 551.
156 . Id. at 553.
157 . Id.
We realize the feelings of professional pride, of ambition to succeed in
their profession of arms, of fear for their personal safety or of reprisals
against their families, their love of country, their soldiers' concept of
obedience, and indeed, the ingrained respect of the German for those in
authority over him, were factors in their decisions. We are aware of the
tendency towards degeneration of "civilized" warfare in the modern concept of
"total" war, and of the war madness that engulfs all people of belligerent
powers.
Id.
158 . Id. at 553-56. The evidence established that criminal orders were
executed by units subordinate to von Leeb and that criminal acts were carried
out by agencies within his command. But, criminal responsibility was not
affixed on the theory of subordination and overall command. "He must be shown
both to have had knowledge and to have been connected with such criminal
acts, either by way of participation or criminal acquiescence." Id. at 555.
159 . Id. at 557-58. Von Leeb's subordinate units were the 18th Army under
von Kuechler, the 16th Army under Busch and the 4th Panzer Group under
Hoepner. Id. at 557. "As a practical purpose, what other action was open to
him? He could not revoke this order coming as it did from his superiors, even
from the head of the state. Had he undertaken to do so, this would have been
a flagrant disobedience of orders . . . ."
Id.
160 . Id. at 560. But see note reporting the use of prisoners to clear land
mines. Id. at 558.
161 . Id. at 559.
162 . Id. at 562.
163 . Id. at 560-61.
164 . Id. at 563.
165 . Id. at 566.
166 . Id. at 567.
167 . Id.
168 . Id. at 577.
169 . Id. at 579.
170 . Id.
171 . Id. at 580.
172 . Id. at 695.
173 . Id. at 581.
174 . Id. at 582.
175 . Id. The German Military Penal Code provided that an officer was not
required to carry out an order that was clearly criminal on its face and that
a officer who carried out such an order was criminally liable. Id.
176 . Id. at 582.
177 . Id. at 596-97.
178 . Id. at 598.
179 . Id. at 598.
180 . Id.
181 . Id. at 599-602.
182 . Id. at 601-02.
183 . Id. at 606-07.
184 . Id. at 696.
185 . Id. at 614-15.
186 . Id. at 618-19.
187 . Id. at 619.
188 . Id.
189 . Id.
190 . Id. at 619-20.
191 . Id. at 621-22.
192 . Id. at 623. In May 1942, while in command of the 17th Army, von Salmuth
distributed an order requiring the registration of all citizens with the
exception of Jews, foreigner and Red Army soldiers. Those who failed or were
prohibited from registering were to be executed along with those who assisted
them in avoiding apprehension. Id. at 625.
193 . Id. at 623.
194 . Id. at 696.
195 . Id. at 630.
196 . Id. at 632.
197 . Id. at 634.
198 . Id. at 636.
199 . Id. at 639.
200 . Id. at 641.
201 . Id. at 644.
202 . Id. at 645.
203 . Id. at 646.
204 . Id. at 648.
205 . Id. at 696.
206 . Id. at 648.
207 . Id. at 651-54.
208 . Id. at 655-56.
209 . Id. at 657.
210 . Id. at 658.
211 . Id. at 659.
212 . Id. at 696.
213 . Id. at 662.
214 . Id. at 665.
215 . Id. at 669.
216 . Id. at 670-71.
217 . Id. at 679.
218 . Id. at 680.
219 . Id. at 683. Rudolf Lehmann was chief of the Legal Department of the OKW
and was convicted of involvement in the drafting and refinement of various
criminal directives, particularly the Barbarossa Jurisdiction Order:
Lehmann became the main factor in determining the final form into which the
criminal ideas of Hitler were put . . . he modified those ideas within his
own sphere up to a certain point and placed the whole into an effective
military order which was transmitted to the troops and carried out.
Id. at 693.
220 . Id. at 696.
221 . EINSATZGRUPPEN MATERIALS, supra note 59, at 15-20 (1950).
222 . Id. at 21-22.
223 . Id. at 22.
224 . Id. at 36-37. On the "complete solution" to the "Jewish question" see
Letter From Goering To Heydrich Concerning Solution Of Jewish Question, 31
July 1941, id. at 132-133.
225 . Opening Statement Of The Prosecution, id. at 30, 36. Einsatzgruppe A
operated in Latvia, Lithuania and Estonia; Eninsatzgruppe B functioned
adjacent to Einsatzgruppe A and its operations extended to Moscow;
Einsatzgruppe C was stationed in Ukraine; and Einsatzgruppe D was responsible
for portions of the Ukraine, the Crimean Peninsula and the Caucasus. See
Affidavit Of Otto Ohlendorf, 24 April 1947, Concerning The Organization Of
The Einsatzgruppen, id. at 92-93.
226 . Opening Statement For The Prosecution, id. at 34. "We Germans who are
the only people in the world who have a decent attitude towards animals will
also assume a decent attitude towards these human animals." Id.
227 . Id. Frank wrote in his diary that "'I cannot eliminate all lice and
Jews in only a year's time.'" Id. at 35.
228 . Id. at 38-39. The Einsatzgruppen also were assigned to exterminate
suspected Bolsheviks who were detained in prisoner-of-war camps. See Extract
>From Operational Order NO. 8, 17 July 1941, id. at 123. Those who were killed
were executed by firing squads. This method of killing later was replaced by
enclosed trucks in which the victims were asphyxiated through the use of
lethal gases. Opening Statement Of The Prosecution, Id. at 40-41. Some Jews
were killed during pogroms organized by the Germans. See Extracts From Report
Of Einsatzgruppe A Covering The period From 23 June 1941 to 15 October 1941,
id. at 154, 155-156.
[T]he four Einsatzgruppen averaged some 1,350 murders per day during a 2-year
period; 1,350 human beings slaughtered on the average day, 7 days a week for
more than 100 weeks. That is 337 murders per average day by each group of 500
to 800 men during a 2-year period . . . . They had to be counted, stripped of
possessions, shot, and buried . . . . [A]ll of the pitiful possessions taken
from the dead had to be salvaged, crated, and shipped to the Reich . . . .
Details of all these things had to be recorded and reported.
Opening Statement Of The Prosecution, id. at 39.
229 . Opening Statement Of The Prosecution, id. at 45.
230 . See Affidavit Of Otto Ohlendorf, 5 November 1945, Concerning The
Extermination Program Of The Einsatzgruppen, id. at 205, 206.
231 . Affidavit Of Walter Blume, 29 June 1947, id. at 139, 140.
232 . Opening Statement Of The Prosecution, id. at 45.
233 . Id.
234 . Affidavit Of Hein Hermann Schubert, 24 February 1947, Concerning The
Extermination Of Jews In Russia, id. at 207-08.
235 . Extracts From The Testimony Of Defendant Ohlendorf, id. at 355, 356.
236 . Extracts From Report Of Einsatzgruppe A Covering The Period From 23
June 1941 to 15 October 1941, id. at 154, 161.
237 . Id. at 162.
238 . Secret Memorandum From Kube, General Commissioner Of White Ruthenia, To
Gauleiter Lohse, Reich Commissioner Of Ostland, 31 July 1942, Concerning
Actions Against Partisans And Liquidation Of Jews In White Ruthenia, id. at
191, 193.
239 . Id.
240 . Extract From Draft Of Memorandum By Einsatzgruppe A, Concerning
Liquidation Of Jews, id. at 197.
241 . See Closing Statement Of The Prosecution, 13 February 1948, By
Brigadier General Telford Taylor, id. at 369, 377, 381-382.
242 . Opening Statement Of The Prosecution, id. at 42.
243 . EINSATZGRUPPEN JUDGMENT, supra note 3, at 587-89. Defendant Emil
Haussmann committed suicide; and defendant Otto Rasch was severed due to
Parkinsonism. Id. at 411. The three members of the judicial tribunal were
Michael A. Musmanno, Presiding Judge, United States Naval Reserve on Military
leave from Court of Common Plea, County of Allegheny, Pennsylvania; John J.
Speight, Member of Alabama Bar; and Richard D. Dixon, Judge of Superior Court
of North Carolina. EINSATZGRUPPEN MATERIALS, supra note 59, at 6.
244 . EINSATZGRUPPEN JUDGMENT, supra note 3, at 412.
245 . Id.
246 . Id. The International Military Tribunal at Nuremberg estimated that the
Einsatzgruppen were responsible for the killing of two million. Id.
247 . Id. at 415. Those to be summarily executed included "Jews, gypsies,
insane people, Asiatic inferiors, Communist functions, and asocials." Id. at
416. The Krimchaks were a Turkish speaking minority in Crimea which had
migrated from the southern Mediterranean. The Germans determined that they
had "Jewish blood" and were to be systematically executed. Id. at 415. These
exterminations extended to prisoners of war who were confined in
concentration camps. Id. at 441-42.
248 . Id. at 417.
249 . Id. at 419.
250 . Id.
251 . Id. at 419-20.
252 . Id. at 432.
253 . Id.
254 . Id. at 491.
255 . Id. at 439. Despite the brutality of their acts, the defendants were
not "untutored aborigines incapable of appreciation of the finer values of
life and living." Eight were lawyers and among the others were a dentist,
university professor, art expert, opera singer and a former minister. Id. at
500. Numerous witnesses testified as to the defendants' virtue, sensitivity
and concern for others. Id. at 501.
256 . Id. at 440.
257 . Id. at 459 (emphasis omitted). "Control Council Law No. 10 is but the
codification and systemization of already existing legal principles, rules,
and customs." Id. at 458. Thus, "Control Council Law No. 10 is not only in
conformity with international law but is in itself a highly significant
contribution to written international law." Id. at 460.
258 . Id. at 460. The Tribunal rejected the argument that Russia had ratified
Germany's aggression against Poland and thus should be prohibited from
assuming the status of a prosecuting power under Control Council Law No. 10.
The Tribunal cited the conclusion of the International Military Tribunal at
Nuremberg that Germany alone was responsible for precipitating the war in
Europe and for committing countless crimes. The onset of the Cold War
following the termination of World War II, in the view of the Tribunal, also
did not disqualify Russia from serving as a Signatory Power. At any rate, the
Tribunal noted that it was concerned with the liability of individuals rather
than States. Id. at 456-58.
259 . Id. at 460.
260 . Id. at 461-62.
261 . Id. at 462.
262 . Id. at 462-63.
263 . Id. at 463. The Tribunal offered a hypothetical scenario in which a
citizen of Abyssinia travelled to Norway and killed a Norwegian whom he
believed posed a threat to his country. If it later was revealed that the
Abyssinian killed the wrong person, under the defendants' theory, he would be
able to claim exoneration based upon his good faith error. Id. "The fact that
this astounding proposition is advanced in all seriousness demonstrates how
desperate is the need for a further revaluation of the sacredness of life and
for emphasizing the difference between patriotism and murder." Id.
264 . Id. at 464.
265 . Id. at 467.
266 . Id.
267 . Id.
The annihilation of the Jews had nothing to do with the defense of Germany,
the genocide program was in no way connected with the protection of the
Vaterland, it was entirely foreign to the military issue. Thus, taking into
consideration all that has been said in this particular phase of the defense,
the Tribunal concludes that the argument that the Jews in themselves
constituted an aggressive menace to Germany, a menace which called for their
liquidation in self-defense, is untenable as being opposed to all facts, all
logic and all law.
Id. at 469-470.
268 . Id. at 470-71.
The obedience of a soldier is not the obedience of an automaton. A soldier is
a reasoning agent. He does not respond, and is not expected to respond like a
piece of machinery. It is a fallacy of wide-spread consumption that a soldier
is required to do everything his superior officer orders him to do . . . .
Even if the order refers to a military subject it must be one which the
superior is authorized, under the circumstances to give. If every military
person were required, regardless of the nature of the command, to obey
unconditionally, a sergeant could order the corporal to shoot the lieutenant,
the lieutenant could order the sergeant to the shoot the captain, the captain
could order the lieutenant to shoot the colonel, and in each instance the
executioner would be absolved of blame. The mere statement of such a
proposition is its own commentary . . . .
Id. at 470.
269 . Id. at 480-81.
270 . Id. at 480.
271 . Id. at 480.
No court will punish a man who, with a loaded pistol at his head, is
compelled to pull a lethal lever. Nor need the peril be that imminent in
order to escape punishment. But were any of the defendants coerced into
killing Jews under the threat of being killed themselves if they failed in
their homicidal mission?
Id.
272 . Id. at 471.
273 . Id. at 480.
274 . Id. at 481-82.
275 . Id. at 482.
276 . Id. at 485.
No soldier would be disgraced in asking to be excluded from so one-sided a
battle. No soldier could be accused of cowardice in seeking relief from a
duty which was, after all, not a soldier's duty. No soldier or officer
attempting escape from such a task would be pleading avoidance of a military
obligation. He would simply be requesting not to be made an assassin. And if
the leaders of the Einsatzgruppen had all indicated their unwillingness to
play the assassin's part, this black page in German history would not have
been written.
Id. at 484-485.
277 . Id. at 475.
278 . Id. at 476.
279 . Id. at 506-09.
280 . Id. at 507.
281 . Id. at 510.
282 . Id. at 511.
283 . Id. at 514.
284 . Id.
285 . Id. at 515.
286 . Id. at 517.
287 . Id. at 518.
288 . Id.
289 . Id. at 517.
290 . Id. at 542-44.
291 . Id. at 547, 549.
292 . Id. at 518.
293 . Id. at 519.
294 . Id. at 529.
295 . Id. at 532.
296 . Id.
297 . HOSTAGE JUDGMENT, supra note 3, at 764-77. The individuals indicted
were Wilhelm List, Maximlian von Weichs, Lothar Rendulic, Walter Kuntze,
Hermann Foertsch, Franz Boehme, Helmuth Felmy, Hubert Lanz, Ernst Dehner,
Ernst von Leyser, Wilhelm Speidel and Kurt von Geitner. Id. at 776-77.
298 . Id. at 765-69.
299 . Id. at 769-72.
300 . Id. at 772-74.
301 . Id. at 774-76.
302 . Extracts from Opening Statement of the Prosecution, HOSTAGE MATERIALS,
supra note 59, at 785, 797. The clergy, intellectuals and members of the
landed gentry were singled out for these retaliatory killings. Id. at 798.
303 . Id. at 798.
Unable to apprehend the persons involved in these attacks, the Nazis
characteristically slaughter fifty or a hundred innocent persons. Those who
would 'collaborate' with Hitler or try to appease him cannot ignore this
ghastly warning.
The Nazis might have learned from the last war the impossibility of breaking
men's spirit by terrorism. Instead, they develop their 'Lebensraum' and 'new
order' by depths of frightfulness which even they have never approached
before. These are the acts of desperate men who know in their hearts that
they cannot win. Frightfulness can never bring peace to Europe. It only sows
the seeds of hatred which will one day bring fearful retribution.
Id. at 798-99.
304 . Id. at 799.
305 . Id. at 800.
306 . Id.
307 . Id.
308 . Id.
309 . Id. at 801.
310 . Id.
311 . See Hitler Order, 16 September 1941, Charging Defendants List And
Boehme With The Task Of Suppressing The Insurgent Movement In Southeastern
Area, id. at 969.
312 . Extracts from Opening Statement of the Prosecution, Id. at 803.
313 . Keitel Order, 16 September 1941, Concerning Suppression Of insurgents
In Occupied Territories," id. at 971, 972 (emphasis omitted).
314 . Id. at 972.
315 . Keitel Order Concerning Taking Of Hostages, 28 September 1941, And
Letter Of Transmittal Signed By Defendant Foertsch, 4 October 1941, id. at
973.
316 . Order Of Commanding General Serbia, Boehme, 10 October 1941, Directing
The Shooting Of 50 And 100 Prisoners Or Hostages For Each German, Or Ethnic
German, Soldier Wounded or Killed, id. at 977.
317 . Id. at 977-78. A directive was distributed to the German population:
1. Anyone who supports the insurgents or their accomplices, by means of arms
and ammunition, by erecting road blocks, by destroying bridges, by
transmitting information, by giving food, by providing transportation, or by
any other manner, will be shot.
2. Anyone who carries fire arms, pointed weapons, hand grenades, or other
weapons, will be shot.
3. Anyone who conceals arms and ammunition will be shot.
4. The communities - in whose areas arms and ammunition are found, in whose
areas road blocks or destroyed bridges are found, without being prevented or
immediately averted by you, in whose area other hostile acts occur - will be
severely punished by the burning down of houses and shooting of inhabitants.
For every killed German soldier, 100 inhabitants will be shot.
. . .
Beware of heavy penalties! Keep peace!
German Proclamation To Serbian Population, October 1941, Announcing The 100:
1 Reprisal Ratio, id. at 979-80.
318 . Order Of Commanding General In Serbia, 4 October 1941, Declaring that
2,100 Concentration Camp Inmates Be Shot For The Killing Of 21 German
Soldiers, id. at 976. See also Extracts from Opening Statement of the
Prosecution, id. at 805.
319 . Extract From Situation Report U.S.S.R. NO.37, 29 July 1941, Concerning
Reprisal Action Against Jews In Belgrade, Id. at 938.
320 . Extracts from Opening Statement of the Prosecution, Id. at 807, 810.
321 . Id. at 809.
322 . Order Of General Boehme, 2 November 1941, Concerning Suppression Of
Serbian Resistance, id. at 993, 994.
323 . Draft Of Teletype From Armed Forces Commander Southeast To Commanding
General Serbia, 6 February 1942, Requesting Reports On All Reprisal Measure,
id. at 999, 1000.
-----
Aloha, He'Ping,
Om, Shalom, Salaam.
Em Hotep, Peace Be,
All My Relations.
Omnia Bona Bonis,
Adieu, Adios, Aloha.
Amen.
Roads End

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