“Weakening Command Responsibility Doctrine? The Bemba Appeals Judgment,” a chapter by University of Georgia School of Law Professor Diane Marie Amann, has just been published in The International Criminal Court: Legal, Policy, and Political Challenges.

Amann, who is Regents’ Professor of International Law, Emily & Ernest Woodruff Chair in International Law, and a Faculty Co-Director of our Dean Rusk International Law Center here at Georgia Law, is a Visiting Academic this semester at University College London Faculty of Laws.

Her commentary on Prosecutor v. Bemba, a 2018 judgment of acquittal by the ICC Appeals Chamber, first appeared as “In Bemba, Command Responsibility Doctrine Ordered to Stand Down.” It then was included in this 2025 Brill Publishers collection, edited by UCLA Law Professor Richard H. Steinberg. Also contributing to the book’s section on the Bemba judgment were attorney Nadia Carine Fornel Poutou and law professors Miles Jackson (Oxford), Michael Newton (Vanderbilt), and Leila Nadya Sadat (Washington University).

Here’s the abstract for Professor Amann’s essay:

“The acceptance of commander’s responsibility is, in effect, acceptance of authority over persons permitted to kill. With that acceptance comes a heavy burden, grown out of practical and moral concerns and reflected in longstanding legal doctrine. At odds with this burden was the judgment of acquittal that the International Criminal Court Appeals Chamber entered in Bemba in 2018. Originally appearing in an online forum, this commentary argues for a statutory construction that better would serve the purposes of the ICC and the command responsibility doctrine.”