Labeling the wars in Iraq and Afghanistan as “freedom” operations, U.S. officials portrayed them as battles between good vs. evil. The war efforts, they argued, would establish democracy, rule of law, and freedom in the place of brutal autocratic regimes that violated human rights. Paradoxically, though predictably, the wars in Iraq and Afghanistan themselves were illegal, undermined democratic principles that the U.S. espoused, and resulted in widespread and systematic human rights violations both at home and abroad, some of which are the subject of this request.
U.S.’s Failure or Refusal to Respect, Protect and Fulfill Rights
to Life, Physical Integrity, Association, Equality,
and Non-Discrimination as Occupier
U.S. promises to promote democracy in Iraq have been shown to be hollow. Soon after the invasion, the U.S. set up the Coalition Provisional Authority (CPA), which served as the transitional government until its dissolution in June 2004. While in existence and under the authority of Paul Bremer, the CPA issued orders which opened the door to foreign investment and attempted to privatize more than 200 state-owned firms. Continuing the CPA’s legacy, between 2009-2010 the Iraqi government granted contracts to 18 oil companies, many foreign, for which the U.S. military provided security, and has allowed them to appropriate valuable farmland. Despite President Bush’s assurance that the U.S. would “work on the development of free elections and free markets, free press and free labor unions in the Middle East,” one law maintained by the CPA was Saddam Hussein’s 1987 law prohibiting unions among workers in the public sector, which constitutes more than 70 percent of the nation’s workforce. The CPA continued to work to prevent unions from organizing, even reportedly arbitrarily arresting eight members of the Iraqi Federation of Trade Unions for their involvement in labor unions with no apparent basis and no explanation ever given. Repression of union activity continues today, most readily apparent in the oil sector with union leaders facing forced transfers and arrests. Iraqi oil ministry spokesman Assam Jihad publicly asserted in 2010, “Unionists instigate the public against the plans of the oil ministry to develop [Iraq’s] oil riches using foreign development.” However, as Iraqis have made clear through demonstrations in the streets, their ability to work with dignity is critical to the country’s healing from war.
The U.S. also heavily influenced the drafting of Iraq’s constitution, which then-U.S. Vice President Dick Cheney described as “progressive and democratic.” But the new Iraq constitution included a religious filter insisted upon by U.S.-backed religious-political extremists who desired to pursue a reactionary agenda to the secularism of the Hussein era. Ultimately the U.S. was responsible for pushing Iraq toward theocracy, helping to broker a constitution that established an official state religion and invalidates any law contradicting established principles of that religion. The new constitution further conditioned the rights to freedom of expression, press, assembly and peaceful protest on “public order and morality,” a qualification subject to wide interpretation and rife with potential for abuse and criminalization of political expression. Women activists in Iraq have pointed to these and related factors, including the Iraqi penal code’s provision allowing men to discipline their wives “within certain limits prescribed by Islamic law, or custom” – channeled into the new era of Iraq governance by the U.S. – as serious setbacks that have served to create a climate in which many forms of violence against women have dramatically increased, particularly in the form of honor killings estimated to have killed thousands of Iraqi women in recent years.
President Bush assured U.S. soldiers that they were “sacrificing for the peace of Iraq and for the security of free nations.” The wars in Iraq and Afghanistan, however, have made these countries less secure and resulted in hundreds of thousands of violent deaths, many of them civilian. In October 2010, Wikileaks released U.S. Army field reports known as the Iraq War Logs (IWL), which gave the first official government tally of the death toll. In total, the IWL detailed 109,032 deaths in Iraq from January 1, 2004 – December 31, 2009, 60.6% (or 66,081) of which were civilian deaths. The IWL only reflect what troops actually witnessed, and organizations that track the loss of civilian life in Iraq estimate the total number of civilian deaths to be much greater. When the non-profit organization Iraq Body Count (IBC) cross-referenced the IWL with its own death count for that time period, it determined that approximately 12,000 civilian deaths were not included in the IWL number. In total, IBC estimates that over 150,000 violent deaths have been recorded since March 2003, with more than 122,000-134,000 (approximately 80-90%) of them civilian. “Excess deaths,” which are those deaths above what would have normally been expected had the war not occurred including indirect deaths due to malnutrition, damaged health infrastructure, and environmental degradation, are much higher still. Researchers from the University of Washington, Simon Fraser University, the Iraqi Ministry of Health, and John Hopkins University estimate that already by 2006 approximately 405,000 people had died directly and indirectly as a result of the war in Iraq.
Likewise, there is a need to assess the number of “excess deaths” on the U.S. side of the equation beyond the numbers of those servicemembers killed in combat. One study in California has noted that the number of veterans under age 35 who died between 2005 and 2008 was three times higher than the number of California servicemembers killed in Iraq and Afghanistan during the same period. Veterans under age 35 were far more likely to commit suicide and die by other means than others of the same age with no military service. Additionally, there are reports of increasing rates of homicide committed by returning veterans, who often also suffer from post-traumatic stress disorder (PTSD) and other mental disorders.
In Afghanistan, the number of civilian deaths is much harder to estimate. In the early days of that war, General Tommy R. Franks famously said, “We don’t do body counts.” In Afghanistan there is also no independent long running tally of civilian deaths like the IBC in Iraq. However, the Costs of War project, a nonpartisan, nonprofit, scholarly initiative based at Brown University’s Watson Institute for International Studies estimates that approximately 16,725-19,013 civilians have been killed in Afghanistan since the initial 2001 invasion. The researchers acknowledge that these are conservative estimates based on third party reporting. What can be lost in these staggering numbers is the story and life of each civilian killed.
Photo by Jon Orlando
As set forth in more detail below, while there is still need for growing understanding and study of the effects of war and traumatic situations on servicemembers sent to fight, such as PTSD and traumatic brain injuries (TBI), far less is known about the prevalence and experience of these same lasting harms among the Iraqi and Afghan populations. In a study undertaken for the World Health Organization and the Iraq Ministry of Health, it was estimated that nearly half of the population suffers from some sort of psychological disorder due to the effects and consequences of the war, including the death of family members, forced displacement and living in a climate of fear and violence. An Iraqi psychologist has estimated that 28 percent of Iraqi children suffer some degree of PTSD and that “their numbers are steadily rising.”
At the same time, there is still much more to be learned about the psychological impacts on returning servicemembers and appropriate and comprehensive institutional responses are urgently needed. Acknowledging that the number of TBI cases is underestimated and underreported, the U.S. government still estimates that over 250,000 troops suffer from this injury. Similarly, the U.S. government estimates that 29% of veterans or one in four returning veterans have been diagnosed with PTSD. These traumatic injuries have become so prevalent in returning veterans that they are often referred to as the “signature wounds” of the Iraq and Afghanistan wars.
Significantly, recent studies have shown that even troops who never set foot in a war zone but who are responsible for directing unmanned aerial (i.e. drone) attacks are reportedly suffering from PTSD as well. Researchers are also continuing to delve more into the nature of “moral injury,” described as the psychological damage caused when servicemembers’ actions in battle conflict with their moral codes. Indeed, the fundamental illegality and injustice of the war is a factor contributing to and exacerbating the psychological harm for some servicemembers. Another indication of the manifestation of the deep harms of these wars is the dramatically elevated suicide rate amongst servicemembers, which is nearly double the civilian suicide rate.
Not least among the policies of the U.S. military that have given rise to serious health consequences are the brutal redeployment policies that exacerbated the trauma of the wars for many servicemembers. The need to redeploy soldiers, often multiple times, exacerbated the already ill effects of policies allowing command discretion over work restrictions deemed ‘medically necessary’ by health care providers—including command override of ‘nondeployable’ medical conditions. The military’s response to the health needs of returning servicemembers has also been deplorable in that it reportedly follows policies which often serve to discharge and deny servicemembers benefits for what are likely the manifestations of illness and trauma encountered during their military service. Indeed, one former Veterans Affairs researcher recently testified before a Congressional panel that officials in the Department of Veterans Affairs routinely manipulate or hide data that would support veterans’ claims so as to avoid paying costly benefits.
As set out further below, Iraqi civilians and U.S. servicemembers share a terrible toxic bond having been exposed to toxic munitions and carcinogenic waste over a decade that will likely have devastating effects for a long time to come. In Iraq, cancer rates, birth defects and other illnesses have reportedly skyrocketed since the U.S. invasion. Depleted uranium in weapons used by the U.S. military in Iraq is believed to have contaminated civilian areas in parts of the country, exposing both Iraqis and U.S. servicemembers to an unparalleled risk of cancer and other illnesses, as well as having children with birth defects. The largely unregulated use of burn pits to dispose of any and all materials, including hazardous waste, on U.S. military bases has left countless veterans with a wide range of illnesses including respiratory and neurological problems and cancer. Despite these grave and widespread harms, the U.S. government has not taken action to study or decontaminate affected civilian areas or help treat the illnesses and health conditions of Iraqis suffering as a result and has failed to provide for servicemembers injured by the toxic exposures. Some veterans who are suffering ill health effects after having been exposed to burn pits have brought civil cases against the private military contractors responsible for burning waste in that manner. In February, a trial court dismissed the cases on the ground that they raised a “political question” (i.e. could only be addressed by the executive and legislative branches of the U.S. government). Following a successful appeal of that ruling, the case is again before the trial court.
Photo courtesy of Al Jeel/OWFI
A mother in Haweeja sits with her child, who
suffers from birth defects and was born near a
U.S. military base after the invasion.
Lasting Effects of the Use
of Inhumane Weapons
In addition to the use of weapons containing depleted uranium and as discussed further below, U.S. officials have admitted to using napalm-class munitions and white phosphorous, an incendiary agent that can burn to the bone, in Fallujah and elsewhere. These weapons were used in operations in populated areas and resulted in harm to civilians. Similarly, the use of cluster munitions, which spread over a wide area and often fail to explode on impact, has resulted in the indiscriminate killing of civilians. The remaining unexploded munitions continue to maim and kill more over time.
Militarized Sexual and Gender-based Violence
Sexual and gender-based violence against civilians in Iraq and Afghanistan, as well as among U.S. military personnel, has been shown to be widespread and systemic. In U.S.-run detention facilities such as Abu Ghraib, sexual violence and psychological torture were commonly inflicted upon both female and male detainees, often in order to elicit information and/or to humiliate and degrade. Likewise, U.S. servicemembers, both male and female, have been subjected to sexual assaults by other members of the military at alarming rates. Preliminary data released by the DOD showed more than 5,000 reports of sexual assaults across the U.S. military in 2013 alone. In 2012, the DOD reported over 3,300 cases of sexual assault while estimating that only 11 percent of sexual assaults were likely reported. In light of this, officials extrapolate that the number of 2012 sexual assaults in the military was in fact about 26,000. A recent Pentagon health study showed that approximately one in five women experienced unwanted sexual contact by another servicemember, with the Marines seeing the highest rate of sexual abuse with 30 percent of women reporting such experiences. The study indicates rates of abuse are higher than suggested by earlier studies.
These types of assaults often result in lasting physical harm and health issues as well as psychological wounds that can manifest into PTSD, increased suicidal tendencies and other serious conditions. Iraqi and Afghan victims of sexual assault at the hands of U.S. military personnel and private U.S. military contractors have seen little justice or compensation for the crimes committed against them. U.S. servicemembers who have experienced sexual assault at the hands of other servicemembers have historically faced daunting challenges in that the policies and practices of the U.S. military have served more often than not to blame the victims of the assaults and leave the perpetrators of assaults in place. Such practices have also often lead to the denial of health benefits to victims when they are suffering physical and/or deep psychological harm as a result of the sexual assaults. In February 2011, twenty-eight veterans of the U.S. military brought a civil case against past and present Secretaries of Defense alleging that they allowed policies and practices that fostered the climate in which the assaults could take place without adequate responses to deter and punish them. A federal judge dismissed the case in December 2011 under a doctrine that prohibits servicemembers from bringing suits against the federal government arising from matters deemed “incident” to their service. An appeal of that decision is currently pending. While President Obama recently signed into law a bill making the investigation and prosecution of military sexual assault cases easier, much more robust provisions for accountability are needed.
U.S.’s Reconstruction Debacle Not a Form of ‘Reparations’
In March 2013, the U.S. Special Inspector General for Reconstruction in Iraq issued its final report on the allocation of U.S. $60 billion intended for reconstruction in Iraq. The report details a myriad of ways in which billions of dollars were ultimately wasted, including as a result of lack of accountability and oversight, which also led to high levels of corruption. The report includes interviews with key Iraqi officials and U.S. officials involved at different levels and stages. The report quotes Iraq’s acting Minister of the Interior as saying, “With all the money the U.S. spent, you can go into any city in Iraq and you cannot find one building or project…You can fly a helicopter around Baghdad or other cities, but you cannot point a finger at a single project that was built and completed by the United States.” With one chapter even entitled “Nation (Re)building by Adhocracy,” the report included other accounts of the U.S.’s failure to build reconstruction projects even in places that suffered widespread destruction as a result of battles waged there, as well as failed projects that in many cases were far over budget, with infrastructure and basic necessities still lacking. The report cited a United Nations report that noted that Iraq had “the second-highest amount of available water per capita in the Middle East,” but “its water quality was poor, violating Iraq National Standards and World Health Organization guidelines.”
It is important to note that the funding allotted by the U.S. to “reconstruction,” which was ultimately mismanaged, misspent and in large part wasted, was never intended as a form of reparations for the damage or harm caused by the illegal war and the violations that flowed from it. Reparation is a principle of international law that holds that the violation resulting from an engagement between states carries an obligation to make reparation in an adequate form. It is particularly relevant in situations of armed conflict. Reparations requires a wrongdoing party to redress damage caused to an injured party and can include restitution, compensation, rehabilitation and satisfaction and guarantees of non-repetition.
In fact, Bush administration officials proclaimed that the Iraq war “would pay for itself”– or more to the point – that Iraq would pay for the U.S.’s war against it. According to then-Defense Secretary Donald Rumsfeld, “the bulk of the funds for Iraq’s reconstruction will come from Iraqis – from oil revenues, recovered assets, international trade, direct foreign investment, as well as some contributions we’ve already received and hope to receive from the international community.” None of the funds the U.S. directed toward Iraq reconstruction were allocated in any sense out of the obligation of a wrongdoer, but of an investor that expected to be able to recoup its investment.
 Speech to the World Affairs Council of Philadelphia by U.S. President George W. Bush, The Struggle for Democracy in Iraq, Dec. 12, 2005.
 James Dobbins, Occupying Iraq: A history of the Coalition Provisional Authority, XIII, RAND Corporation (2009); Seth G. Jones et al., Records From Coalition Provisional Authority Shed Light on Occupation of Iraq, RAND Corporation, May 12, 2009, available at http://www.rand.org/news/press/2009/05/12.html.
 Matthew Harwood, Pinkertons at the CPA: Iraq’s Resurgent Labor Unions Could Have Helped Rebuild the Country’s Civil Society. The Bush Administration Of Course Tried to Crush Them, Washington Monthly, Apr. 2005, available at http://www.washingtonmonthly.com/features/2005/0504.harwood.html.
 David Bacon, For Unionists, Iraq’s Oil War Rages On, In These Times, Apr. 2, 2013, at http://inthesetimes.com/article/14808/for_unionists_iraqs_oil_war_rages_on/.
 Text of President Bush’s 2004 State of the Union Address, Washington Post, Jan. 20, 2004 (emphasis added).
 Harwood, supra note 6; See also David Bacon, Saddam’s Labor Laws Live On, The Progressive, Dec. 2003, available at http://www.progressive.org/dec03/bac1203.html.
 See Steve Early, Iraqi Labor Unions Still Struggling with U.S. Occupation’s Yoke, Labor Notes, Aug. 21, 2012, available at http://www.labornotes.org/blogs/2012/08/iraqi-labor-unions-still-struggling-us-occupation%E2%80%99s-yoke; David Bacon, From National Pride to War Booty, CorpWatch, Dec. 15, 2003, at http://www.corpwatch.org/article.php?id=9408.
 Bacon, supra note 7.
 Yifat Susskind, MADRE, Promising Democracy, Imposing Theocracy: Gender-Based Violence and the US War on Iraq, Mar. 2007, available at http://www.madre.org/index/resources-12/human-rights-reports-56/promising-democracy-imposing-theocracy-gender-based-violence-and-the-us-war-on-iraq-86.html#sub1.1 (quoting Dick Cheney, Vice President’s Remarks at a Luncheon for Arizona Victor 2006, Aug. 15, 2006).
 See generally id. Iraq Constitution, Art. 2, Section A, available at http://www.wipo.int/wipolex/en/details.jsp?id=10027.
 Id. at Art. 36.
 Interview with Yanar Mohammed, Director of Organization for Women’s Freedom in Iraq, Feb.1, 2013; E-mail from Yanar Mohammed, Director of Organization for Women’s Freedom in Iraq, Jan. 20, 2014. See also Susskind, supra note 12; Nadje Al-Ali and Nicola Pratt, Conspiracy of Near Silence: Violence Against Iraqi Women, Middle East Report, Spring 2011, available at http://costsofwar.org/sites/default/files/AlAliPrattgender.pdf; United Nations Assistance Mission to Iraq (UNAMI), Human Rights Report: 1 July 2008-31 December 2008, at ¶ 37, available at http://www.ohchr.org/en/Countries/MENARegion/Pages/UNAMIHRReports.aspx.
 U.S. President George W. Bush, Speech to National Endowment for Democracy, available at http://georgewbush-whitehouse.archives.gov/news/releases/2003/11/20031106-2.html.
 Human Costs of War Chart: Direct War Death in Afghanistan, Iraq, and Pakistan, October 2001- February 2013, available at http://costsofwar.org.
 The IWL provides U.S. government data taken from January 1, 2004 – December 31, 2009 denoting every “Significant Action of War” as documented by U.S. Forces abroad. Iraq War Logs, available at WikiLeaks, http://www.wikileaks.org/irq.
 John Tirman, The Forgotten Wages of War, New York Times, Jan. 3, 2012, available at http://www.nytimes.com/2012/01/04/opinion/the-forgotten-wages-of-war.html?_r=0.
 Iraq Body Count, http://www.iraqbodycount.org/analysis/numbers/warlogs/.
 Hagopian A, Flaxman AD, Takaro TK, Esa Al Shatari SA, Rajaratnam J, et al., Mortality in Iraq Associated with the 2003–2011 War and Occupation: Findings from a National Cluster Sample Survey by the University Collaborative Iraq Mortality Study (2013) PLoS Med 10(10): e1001533. doi:10.1371/journal.pmed.1001533. A prior study conducted by some of the same researchers had estimated over 650,000 excess deaths as of 2006. See Gilbert Burnham, The Human Cost of the War in Iraq: a Mortality Study, 2002-2006, Johns Hopkins University, Al Mustansiriya University, and Massachusetts Institute of Technology (2006). The Hagopian et al. study cited here explains the discrepancy: they studied “at least twice the number of clusters as Roberts et al. and Burnham et al.—albeit with the same sample size” and “selected the sample using a more sophisticated randomization approach.” Hagopian, at 11.
 Aaron Glantz, After Service, Veterans Deaths Surge, New York Times, Oct. 16, 2010, available at http://www.nytimes.com/2010/10/17/us/17bcvets.html?pagewanted=all.
 See, e.g., David Philipps, Casualties of War, Part II: Warning Signs, The Gazette, Jul. 28, 2009, available at http://www.gazette.com/articles/html-59091-http-gazette.html.
 Tirman, supra note 20.
 Neta C. Crawford, Civilian Death and Injury in Afghanistan 2001-2011, Sept. 13, 2011, available at http://costsofwar.org/sites/default/files/CrawfordAfghanistanCasualties.pdf.
 Human Costs of War Chart: Direct War Death in Afghanistan, Iraq, and Pakistan, October 2001- February 2013, available at http://costsofwar.org/sites.
 Crawford, supra note 28.
 See Paula Mejia, Wounds of War: PTSD in Iraqis and Veterans, The Majalla, Oct. 10, 2010, available at http://www.majalla.com/eng/2010/10/article55165470; Iraqi Mental Health Survey Study Group, The Prevalence and Correlates of DSM-IV Disorders in the Iraq Mental Health Survey, 8 World Psychiatry 97 (June 2009). In addition to the factors set out above, the study also recognizes the contributing factor of torture during the three decades under Saddam Hussein’s rule to the population’s mental health.
 César Chelala, Iraqi Children: Bearing the Scars of War, The Globalist, Mar. 21, 2009, available at http://www.theglobalist.com/StoryId.aspx?StoryId=7621. See also Lourdes Garcia-Navarro, Treating Iraqi Children for PTSD, National Public Radio, Aug. 25, 2008, available at http://www.npr.org/templates/story/story.php?storyId=93937972.
 U.S. Congressional Research Service, U.S. Military Casualty Statistics: Operation New Dawn, Operation Iraqi Freedom, and Operation Enduring Freedom, Feb. 5, 2013.
 U.S. Congressional Research Service, Report R41921: Mental Disorders Among OEF/OIF Veterans Using VA Health Care: Facts and Figures, Feb. 4, 2013.
 See Elizabeth Bumiller, Air Force Drone Operators Report High Levels of Stress, New York Times, Dec. 18, 2011, available at http://www.nytimes.com/2011/12/19/world/asia/air-force-drone-operators-show-high-levels-of-stress.html?_r=0.
 See Pauline Jelinek, War Zone Killing: Vets Feel ‘Alone’ in Their Guilt, Associated Press, Feb. 22, 2013, available at http://bigstory.ap.org/article/im-monster-veterans-alone-their-guilt.
 See, e.g., Chris Hedges, The Crucifixion of Tomas Young, TruthDig, Mar. 10, 2013, available at http://www.truthdig.com/report/item/the_crucifixion_of_tomas_young_20130310.
 Id.; Nancy Berglass and Dr. Margaret C. Harrell, Losing the Battle: The Challenge of Military Suicide, Center For New American Security, Oct. 2011, available at http://www.cnas.org/publications/policy-briefs/losing-the-battle-the-challenge-of-military-suicide#.Ut1kxBw8Iy4.
 Kelly Kennedy, Researcher: Vets’ Health Data Was Covered Up: Former VA Researcher to Testify Today Before House Panel, USA Today, Mar. 13, 2013, available at http://www.usatoday.com/story/news/nation/2013/03/13/whistleblower-alleges-veterans-affairs-cover-up/1979839/.
 Adam Levine, Halliburton, KBR sued for alleged ill effects of ‘burn pits’, CNN, Apr. 28, 2009, available at http://articles.cnn.com/2009-04-28/us/burn.pits_1_burn-toxic-fumes-plaintiffs?_s=PM:US.
 In re: KBR Burn Pit Litig., No. RWT 09md208, 2013 WL 709826 (D. Md. Feb. 27, 2013), available at http://www.mdd.uscourts.gov/Opinions/Opinions/InReKBRInc._BurnPitLitigation_MemoOpinion.0213.pdf.
 Reported Sexual Assaults in Military Increase, N.Y. Times, Dec. 27, 2013, available at http://www.nytimes.com/2013/12/28/us/reported-sexual-assaults-in-military-increase.html?nl=todaysheadlines&emc=edit_th_20131228&_r=1&.
 U.S. Department of Defense, Department of Defense Annual Report On Sexual Assault in the Military: Fiscal Year 2012, Apr. 2013, at http://www.sapr.mil/index.php/annual-reports [hereinafter SAPRO Report 2012] at 18, 57.
 Id. at 12.
 Greg Zoroya, More Female Service Members Reporting Sexual Abuse: Abuse Rate Appears Significantly Higher Than Similar Survey Findings in 2008, USA Today, April 23, 2013, available at http://www.usatoday.com/story/news/nation/2013/04/22/women-military-sexual-assault/2103075/.
 While some low-level U.S. military personnel were court-martialed and convicted for their role in the abuses at Abu Ghraib, little to no compensation was provided to the victims. A class action civil suit brought against private military contractors at Abu Ghraib in Saleh v. Titan was dismissed in 2009, and while one suit brought by 72 Abu Ghraib detainees against a private contractor, in Al-Quraishi v. L-3 Services, reached a settlement in 2012, another brought on behalf of four detainees, in Al Shimari v. CACI Int’l, was recently dismissed on jurisdictional grounds and is currently being appealed.
 See Cioca, et al., v. Rumsfeld, et al., C.A. 1:11cv00151, Complaint (E.D. Va.).
 See Cioca, et al., v. Rumsfeld, et al., C.A. 1:11cv00151, Defendants’ Motion to Dismiss (E.D. Va.).
 Jon Garcia, Obama Signs Bills to Stave Off Shutdown, Target Military Sexual Assaults, abcnews.com, Dec. 26, 2013, available at http://abcnews.go.com/blogs/politics/2013/12/obama-signs-bills-to-stave-off-shutdown-target-military-sexual-assaults/.
 See, e.g., Congress approves limited protections for military sexual assault victims, Al Jazeera America, Dec. 20, 2013, at http://america.aljazeera.com/articles/2013/12/20/sexual-assault-military.html.
 Special Inspector General for Iraq Reconstruction, Learning from Iraq: A Final Report From the Special Inspector General for Iraq Reconstruction, Mar. 2013, available at http://www.sigir.mil/learningfromiraq/index.html.
 Id. at 14.
 Id. at 81.
 Chorzow Factory Case (Ger. V. Pol.), (1928), Permanent Court of Arbitration, P.C.I.J., Sr. A, No. 17 at 29.
 See, e.g., Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, adopted and proclaimed by General Assembly resolution 60/147 of Dec. 16, 2005.
 Dan Murphy, Iraq War: Predictions Made, and Results, A Look Back at Some of the Predicted US Outcomes for the Iraq War, and What Happened, The Christian Science Monitor, Dec. 22, 2011, available at http://www.csmonitor.com/World/Backchannels/2011/1222/Iraq-war-Predictions-made-and-results.