United States v. Rockwood

48 M.J. 501 (1998)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

United States v. Rockwood

United States Army Court of Criminal Appeals
48 M.J. 501 (1998)


Army Captain Lawrence Rockwood (defendant) was a counterintelligence officer who traveled to Haiti as a member of a United States military joint task force. This joint task force was part of a larger United Nations multinational task force that was working to restore peace and security following instability in Haiti’s government. Rockwood became aware of intelligence reports that the prisoners at Haiti’s national penitentiary were experiencing conditions severe enough to potentially qualify as human-rights abuses. Rockwood reported the information to his superiors, the staff judge advocate’s office, and the division chaplain, and he attempted to initiate an investigation into the penitentiary’s conditions. However, Rockwood’s superiors were focused on operational security concerns and did not authorize an immediate inspection of the penitentiary. Rockwood filed a complaint with his unit’s inspector general, claiming that the joint task force was ignoring probable human-rights violations. A few hours later, without authorization, Rockwood went to personally inspect the penitentiary’s conditions. Because Rockwood was on this unauthorized personal trip, he failed to report for his duty shift that evening. A court-martial convicted Rockwood of several crimes relating to his disobedience. On appeal, Rockwood argued that his disobedience was necessary to avoid international criminal liability because (1) the United Nations task force, including the United States joint task force, was occupying Haiti and (2) as a member of that occupying task force, Rockwood had an individual legal duty under international law to prevent and respond to human-rights violations. Rockwood claimed that this individual duty was created by general international law, the prosecution against General Yamashita for allowing troops under his control to commit war crimes during World War II, and the Nuremberg-defense cases that had held individuals accountable for human-rights violations even though the individuals had a domestic legal duty to commit those violations.

Rule of Law


Holding and Reasoning (Carter, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 734,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 734,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 734,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership