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32 Colum. Hum. Rts. L. Rev. 429 (2000-2001)
Holding Individual Leaders Responsible for Violations of Customary International Law: The U.S. Bombardment of Cambodia and Laos

handle is hein.journals/colhr32 and id is 437 raw text is: HOLDING INDIVIDUAL LEADERS
by Nicole Barrett*
So we ended the Cambodia operation still on the long route
out of Vietnam, confronting an implacable enemy and an
equally implacable domestic opposition. The ultimate vic-
tims of our domestic anguish were the gentle people of
There have been many terrible abuses of humanitarian law
and customary international law stemming from official policy deci-
sions that loom large in history-the Holocaust of the Jews and the
dropping of the atom bombs on Hiroshima and Nagasaki during
World War II, to name only two. In response to the massive destruc-
tion of World War II and in hope of preventing future wars, the in-
ternational community formed the United Nations (U.N.) and began
codifying longstanding principles of international law in treaty form.
In 1949, the three existing Geneva Conventions that codified princi-
*    B.A., Stanford University (1991); M.I.A., School of International and Public
Affairs, Columbia University (1995); J.D., Columbia University School of Law (ex-
pected 2001); Articles Editor, Columbia Human Rights Law Review (2000-2001). I ap-
preciate the assistance of Reed Brody, Michael Ratner, Professor Jose Alvarez, and
Shana Fulton in the preparation of this paper.
1.   Henry Kissinger, White House Years 517 (1979). Kissinger argues that
Cambodians were harmed by the premature withdrawal of United States military op-
erations from Cambodia at the orders of the U.S. Congress.

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