## Facts

- Captain Lawrence P. Rockwood II, a U.S. Army counterintelligence officer, deployed to Haiti in 1994 with Joint Task Force 190 during Operation Uphold Democracy.
- Rockwood received reports through intelligence channels describing severe abuses and harsh conditions in Haitian detention facilities, including the National Penitentiary.
- He raised concerns through military channels, including to superiors, the staff judge advocate’s office, and the division chaplain, and sought an inquiry into prison conditions.
- Command leadership prioritized force protection and mission security and did not authorize Rockwood to conduct an immediate inspection.
- Rockwood filed an Inspector General complaint alleging the task force was failing to respond to probable human-rights violations.
- Shortly after filing the complaint, Rockwood left his unit area without authorization to visit the National Penitentiary on his own initiative to inspect conditions.
- Because he left without authorization, Rockwood also failed to report for his scheduled duty shift.
- He declined an offered nonjudicial disposition and the opportunity to resign, and the case proceeded to a general court-martial.
- An officer panel convicted him of offenses tied to his unauthorized departure, failure to go to his appointed place of duty, and disobedience-related misconduct.

## Issues

1. Whether Rockwood’s actions were legally excused by justification, necessity, or duress based on asserted personal duties under international law to prevent or respond to human-rights abuses.
2. Whether alleged command interest in the case constituted unlawful command influence that denied Rockwood a fair trial.
3. Whether the military judge committed reversible error by denying broad member disqualification requests and limiting defense witness production.
4. Whether the evidence was legally and factually sufficient to sustain the convictions.

## Decision

- The Army Court of Criminal Appeals affirmed the findings and sentence.
- The court held the evidence was legally and factually sufficient to prove the charged misconduct arising from Rockwood’s unauthorized inspection and resulting absence and disobedience-related conduct.
- The court rejected international-law-based justification, necessity, and duress theories as not satisfying the elements of those defenses on the record presented.
- The court found no prejudicial unlawful command influence.
- The court found no reversible error in member impartiality rulings or in the denial of certain defense-requested witnesses.

## Legal Principles

- Necessity, justification, and duress require proof of legally recognized elements (including imminence, lack of reasonable lawful alternatives, and a direct causal link between the misconduct and avoidance of harm); moral urgency alone does not satisfy these defenses.
- Claims that international law imposes a personal duty to act do not, without a showing meeting the elements of a recognized defense, excuse disobedience of lawful orders or abandonment of assigned duties within a military command structure.
- Unlawful command influence requires evidence of improper coercion or influence on the court-martial process; command interest, without demonstrable prejudicial effect on the proceedings, does not warrant reversal.
- Rulings on member challenges and witness production are reviewed for abuse of discretion and require a showing of prejudice to obtain relief.

## Conclusion

The court held that Rockwood’s humanitarian motivations and international-law arguments did not provide a legal defense for leaving his post and disobeying operational constraints, and it found no trial-level errors— including unlawful command influence, panel impartiality, or witness-production rulings—requiring reversal.


United States v. Rockwood, 48 M.J. 501 (A. Ct. Crim. App. 1998)