Judicial Ethics: containing the dubious aroma of uninhibited judicial conduct

The recent descriptions of the behavior of some of our justices and particularly their attempts to defend their conduct have not just raised my eyebrows; they’ve raised the whole top of my head. Lavish, no-cost vacations? Hypertechnical arguments about how a free private airplane flight is a kind of facility? A justice’s spouse prominently involved in advocating on issues before the court without the justice’s recusal? Repeated omissions in mandatory financial disclosure statements brushed under the rug as inadvertent? A justice’s taxpayer-financed staff reportedly helping to promote her books? Private school tuition for a justice’s family member covered by a wealthy benefactor? Wow.

Michael Ponsor, Senior Judge on the US District Court for the District of Massachusetts, A Federal Judge Asks: Does the Supreme Court Realize How Bad It Smells? New York Times, 14 July 2023

On 11 November 2023, I had the privilege of being a panelist at the International Association of Conference Interpreters (AIIC) 14^th Legal Symposium organized by the AIIC Netherlands Chapter on Ethics in Law and Interpreting: Lawyers and Interpreters Talk Ethics: Mutal Expectations, Shared Experiences, which I have already written about. With a couple of international judges on the panel – Kosovo Specialist Chamber Judge Guénaël Mettraux and International Criminal Court (ICC) Judge Joanna Korner – the issue of judicial ethics and codes of conduct was bound to come up. And it did.

Kicking off the discussion, Judge Mettraux touched on judicial ethics and fielded a couple of questions. He stressed, appropriately, the importance of judicial comportment and restraint both inside and outside the courtroom. He recounted how the judges at the International Criminal Tribunal for the former Yugoslavia (ICTY) came to the realization that a judicial code of conduct was needed, and ultimately adopted.

I have long maintained that if the judicial process is not fair, the outcome is meaningless. In the broader sense, it is about procedural justice. Ineluctably, this includes judicial behavior. If court decisions and judgments and sentences are to be accepted as the results of substantive and procedural justice having been served, it is incumbent that the public – nationally and internationally – have confidence in the integrity, independence, and impartiality, of the judges. To that end, codes of conduct provide guidance, albeit framed as general principles requiring the exercise of reason, common sense, and informed judgment.  Codes of conduct also provide a measure of comfort to litigants and the public by telling them that the system is committed to a level playing field.

Listening to Judge Mettraux describe his lifestyle as bland and boring now that he is cocooned as a judge mindful of the judicial decorum by which he must abide, I recalled a conversation I had about 33 years ago with Judge Roy Madsen when I was a public defender in Kodiak Island, Alaska. Though I appeared in court before him almost every day for over three years, we rarely spoke outside the court room. Raised in Kodiak, the first Native Alaskan to sit as a Superior Court (first instance) judge, he was wise, patient, even-handed, and practical. Though a pilar of the community, you rarely saw Judge Madsen at any of the community or social events. You heard even less of him. I did run into him once at a function held at the Russian Orthodox priest’s house. I still recall the encounter – which like others that I have had with judges of like character and moral rectitude – has enriched my understanding of the judicial process and legal profession in general.

In the presence of the priest, I asked Judge Madsen, who was about to retire, how he enjoyed being on the bench for the past couple of decades. A man of few words, uttered in barely audible tone, Judge Madsen told of the solitude of being a judge. He likened it to being in a monastic order. Everything he did and said was being watched and heard. He could not speak his mind on issues he might have wanted his opinion heard. He was always worried that anything he did or said would be taken out of context or might have the effect of calling into question his impartiality – his efforts to see that justice was not only done but seen to be done.

A model of propriety, vigilantly maintaining his independence, his integrity, his impartiality by avoiding even the slightest whiff of conflict of interest. The priest thought Judge Madsen was perhaps too vigilant. Jokingly, he complained that once he had to appear in court for a traffic violation – a matter that normally Judge Madsen would not handle. To the priest’s delight, sitting on the bench was his friend and avid Russian Orthodox churchgoer the Honorable Roy Madsen. Without prompting (sua sponte in legalese), Judge Madsen raised the potential conflict of interest of sitting in judgment of his friend and religious/spiritual leader, asking the parties if objected to him hearing the matter. Come sentencing, Judge Madsen meted out a stern lecture and a hefty (higher than normal) fine. Explaining his sentence to a packed courtroom, he noted that both he and the priest should be community models, setting an example. The priest should abide by all traffic regulations, including the speed limit imposed by law. He on the other hand, had to show that special treatment will be afforded to none; the higher sentence should allay any claims of fear or favoritism. On reflection, the priest came to appreciate the lecture and fine, even though initially he thought Judge Madsen, as his friend, and as his priest, should have cut him some slack. Perhaps a small point, which certainly does not detract from Judge Madsen’s legacy, I, on the other hand, wondered if by going out of his way to impose a higher sentence, Judge Madsen displayed a different, and perhaps equally pernicious bias. The wisdom of recusal lies in its application to any inclination toward a party, whether to favor or disfavor.

Judge Madsen’s integrity was not the exception. In my 40-some years of practice, rarely have I come across unethical – not to be confused with unqualified – judges. I attribute this to a strong sense of moral duty, abiding commitment to public service, and adherence to codes of conduct, accompanied by stimulative measures should they be tempted to stray. Codes of conduct transparently place necessary and time-honored ethical constraints on judges.

Judges are neither special nor immune to engaging in what Judge Ponsor calls conduct with a dubious aroma. The notion that judges or justices are uniquely able to self-monitor and self-regulate their conduct without a code and without stimulative measures and disciplinary modalities is a myth. Like prosecutors – and counsel representing accused, victims, or states – judges the world over must have a code of conduct that guides and restrains them. And even with a code, judges are expected to monitor and adjust their behavior even if certain conduct does not breach a formal rule but would otherwise undermine public confidence in a judge’s independence and impartiality and integrity – and of the court in which s/he sits. Or more succinctly put:  if it smells off, don’t eat it.

With judicial ethics coming at the end of Judge Mettraux’s presentation, I decided to frolic a bit on my favorite field of judicial ethics before giving my presentation. Taking aim at US Supreme Court Justices Clarence Thomas and Samuel Alito for their deplorable and unethical conduct, I questioned Chief Justice John Roberts’ refusal to adopt a code of conduct for the Justices of the US Supreme Court. Shocking and scandalous.

Two days later, on 13 November 2023, as I was pondering whether to write something on judicial ethics, there was breaking news from the New York Times. It was if it was from my lips to God’s ears: the US Supreme Could had adopted a binding ethical Code of Conduct for the Justices of the Supreme Court of the United States (“Code”).

The US Senate has been pressing for some time, even going so far as to invite Chief Justice Roberts to appear (presumably under oath) and answer questions. Aside from the merciless publicity resultant from the pile-on of constant new revelations about Justice Thomas’s many and varied ethics lapses, some credit, much I would say, should be given to Senior Judge Michael Ponsor of US District Court for the District of Massachusetts.

Independent and with life tenure, Judge Ponsor, who has been on the Federal Bench since 1984, elegantly excoriates the Justices of the US Supreme Court in his New York Times opinion article. They may sit above him. They may trump his authority. And in principle, they may be his superiors. Yet, Judge Ponsor fearlessly said what needed to be said. The stench of judicial impropriety by some of the Justices is as repugnant as their verbal contortionism and mental gymnastics in rationalizing the irrational – not to mention puerile and laughable. Even ordinary Joe and Jane with little to no education would instinctively, reflexively know the wrongness of the Justices’ actions from the practical ethics and moral teachings learned as a child at home, at school, in places of worship, and that the excuses and rationalizations of the two Justices miserably fail the smell test.

Perched on Mount Olympus, these judicial gods – unlike Judge Ponsor and his fellow district (first instance) and circuit (second instance) federal judges (all demi-gods in their own right) – have not been subject to a written code of conduct. It’s as if once having ascended to the peak and donned the Supreme Court robe, they were transformed from mortals, with all the human frailties to be guarded against, to virtuous supreme beings.

Self-anointed paragons of unquestionable judicial rectitude, immune from temptation and transgression of unseemly and inexcusable conduct, the Justices brooked no prompting for adopting a code of conduct. It may be a wee bit of an overstatement, in that the Justices are expected to comport themselves in the same way as other federal judges so as not to bring the Supreme Court into disrepute. Even the Justices are not hubristic enough to think that they are above the law – that besides injuring the reputation of the Supreme Court and diminishing public confidence in it as the third pilar of US democracy, they cannot be held to account.

The US Supreme Court has lost its shine – years ago. Partly because many of its judicial decisions are viewed as politically/ideologically driven, and partly because of how some Justices are seemingly influenced by external forces. With scandal after scandal being reported – primarily concerning Justice Thomas’s transgressions bordering on, in my opinion, criminal behavior (tax evaders are routinely prosecuted in US federal courts) – Chief Justice John Roberts seems to have come around. Somewhat.

Justice Roberts and the other Justices must have read Judge Ponsor’s article where he suggests (a no-brainer): “[e]ven a nonenforceable code that the justices formally pledged to respect would be an improvement on the current void.” I am speculating, but, essentially, that is what the Supreme Court adopted – a nonenforceable code.

At an eye-popping length of eight pages, with an additional five and a half pages of general commentary, the four-canon Code is wanting. It is as if the Justices wanted to put out something, anything, to quell the criticism of there being nothing. With Justices being enriched and entertained by wealthy patrons with business and personal (political/ ideological) interests hanging in the Supreme Court balance, you would think a code with teeth would be in order. Yet, despite the massive failures of moral, professional, and ethical conduct by some Justices, and the obvious failure of their supposed self-monitoring and self-regulation, the Code provides no disciplinary modalities.

The Code is a start, not the end. Offering guidance to the Justices in the form of thematic and aspirational refrains, it leaves sufficient wiggle room for interpretation and mischief (Justices by virtue of their tradecraft are superb hairsplitters, or as my friend Alan Yatvin would alliterate: preeminent practitioners of partiality pilpul). With no real oversight for their conduct other than themselves, US Senators who pushed for the Code are unmoved, viewing it with jaundiced eye. And perhaps rightly so.

The Code essentially cherry picks from the Code of Conduct for US Judges. The reason for not adopting it wholesale is that some parts of the code of conduct for the lower federal court judges – by virtue of their functions – did not apply. No explanation is given why a disciplinary regime is not included, or why there is no mention of the Justices being subject to the Judicial Conduct and Disability Act of 1980, explicitly refenced in the Code of Conduct for US Judges. Interestingly, the Code does reference the Judicial Conference Regulations on Gifts, which, incidentally, as part of the Ethics Reform Act of 1989, had been in existence before Justice Thomas ascended to the Supreme Court in 1991. Justice Alito ascended to the Supreme Court in 2006, having served as a Federal Circuit Court Judge, where he would have known of and been subject to the Code of Conduct for US Judges.

What is even more interesting is the recalling and recommitment aside in the last sentence to Canon 4. H. of the Code, “Compensation, Reimbursement, Financial Reporting”:

For some time, all Justices have agreed to comply with the statute governing financial disclosure, and the undersigned Members of the Court each individually reaffirm that commitment.

Odd that this would be included in the Code. If something is in a binding code, would not the Justices be bound by it irrespective of their individual commitment to abide by it? And why insert this silly statement in the Code? By their oath are they not obligated to “faithfully and impartially discharge and perform all the duties incumbent upon [them] under the Constitution and laws of the United States”? Maybe I am missing something.

Chief Justice Roberts notes in the Statement of the Court (a preamble of sorts) that:

For the most part these rules and principles are not new: The Court has long had the equivalent of common law ethics rules, that is, a body of rules derived from a variety of sources, including statutory provisions, the code that applies to other members of the federal judiciary, ethics advisory opinions issued by the Judicial Conference Committee on Codes of Conduct, and historic practice. The absence of a Code, however, has led in recent years to the misunderstanding that the Justices of this Court, unlike all other jurists in this country, regard themselves as unrestricted by any ethics rules. To dispel this misunderstanding, we are issuing this Code, which largely represents a codification of principles that we have long regarded as governing our conduct.

I agree that not much new is in the Code. That the Supreme Court may also have had the “equivocal common law rules of ethics” is also somewhat correct, though as current events show, some Justices are not complying with these common law rules of ethics, and more dramatically, their non-compliance – which assuredly results in ethical breaches and tarnishes the integrity of the Supreme Court – is being tolerated.

The absence of any disciplinary action fosters the notion of acquiescence and accommodation to ethical breaches. Hence the need for a code with disciplinary modalities. As for the claim of misunderstanding that the Supreme Court Justices unlike other jurists (state and federal judges) regard themselves as unrestricted by any ethics rules, their actions speak for themselves.  

The Code is a welcome beginning, but the debate is far from over. I suspect nothing much will change with the Code. Expect no disciplinary modalities being adopted. Is this nonenforecable Code better than nothing? Judge Ponsor thinks so – provided the Justices have functioning noses sensitive to dubious aromas.

And what of judicial ethics and codes of conduct at the international(ized) criminal tribunals and courts?

The judges at the International Military Tribunals (IMTs) in Nuremberg and Tokyo had no code of conduct. Though I have not researched to what extent this may, if at all, handicapped the integrity of the judges’ conduct, I have in the past noted Chief Prosecutor Robert Jackson’s ethical infractions – in particular, his predilection for ex parte communications with some judges he believed (and likely expected) to be sympathetic to supposed difficulties and amenable to his entreats. As a sitting US Supreme Court Justice while also the Chief Prosecutor, Jackson knew better than to try to game the process. Yet that is what he was attempting to do. The judges did not accommodate him. Nonetheless, granting Jackson an ex parte audience bespeaks of the absence of a code that might have guided the judges’ behavior (civil law judges, especially German judges, have a habit of ex parte communication, relying on self-constraint – something I find troubling because it leads to rational perceptions of bias and the risk of unconscious bias). Jackson’s ex parte communications did not impact the trial proceedings or the results one iota. Yet, it is not about no harm, no foul. Harking back to what I’ve noted earlier, procedural justice is an integral part of the process, from which judicial behavior is inseparable.

Like the IMTs, the ICTY initially had no judicial code of conduct. This oversight or deliberate decision by the judges to exclude themselves from an enforceable code was grievous. It did not take very long before it was apparent that some judges were simply ignorant of or indifferent to their ethical obligations. Frankly, this should not have come as a surprise.

Many of the judges had never stepped into a courtroom as a judge, prosecutor, or lawyer. They may have had academic or diplomatic credentials, but, with humility, what do academics and diplomats who have never practiced law really know about the intricacies of litigation and involvedness of ethics, especially concerning judicial decorum and rectitude.

Not that it can’t be picked up from on-the-job learning and observing experienced career judges – not to be confused with “professional” judges, a self-selected moniker bestowed on all judges, distinguishing them from lay jurors. But once a judge was sworn in, s/he was independent. Unless the untrained, unexperienced, unexposed “professional” judge made an effort to learn from many of the very fine judges with whom they had the privilege to serve with (and not all did), a code of conduct with enforcement modalities would have at least provided sufficient ethical guidance.

The codes of conduct for judges at the international(ized) tribunals and courts (here, here, here, here, here) are short and thematic, with broadly framed refrains, ranging from four to ten pages. All cite in the preamble the United Nations Basic Principles on the Independence of the Judiciary (1985). All effectively incorporate the Bangalore Principles of Judicial Conduct (2002) by stipulating that judges carry out their judicial functions with independence, that they not engage in any activity that would interfere with their judicial functions or affect confidence in their independence, that they be impartial, and that they avoid conflicts of interests. As framed, however, the codes leave it up to the judges to figure out the ethical contours. When, for instance, is a judge’s conduct above reproach to the reasonable observer? Ditto for determining a conflict of interest serious enough to warrant a judge to be recused? There are few black and white answers. Depending on where the judge hails from, s/he will approach and appreciate the impugned conduct differently.

With no commentary available for more specific guidance, judges are left to their own devices. Presumably during plenary sessions or retreats (as periodically held by ICC Judges) ethical issues are also covered (one hopes). Presumably some orientation on judicial ethics is available, if not mandatory, for newly minted judges (one hopes). After all, can a diplomat-turned-judge, with no prior practical experience in the goings-on of trial and judicial settings, fully grasp the ethical complexities involved without some guidance from peer judges of vast national and international experience?

Recently, the Ecole Nationale de la Magistrature, the International Nuremberg Principles Academy and the Siracusa International Institute for Criminal Justice and Human Rights, with the involvement of a few international criminal law judges, academics and others, fashioned the Ethical Principles for International Criminal Judges (Nuremberg Principles) for judges to consider in conjunction with their codes of conduct. A good, but only half-step in the right direction. The draft should have been circulated to a wider range of qualified jurists and practitioners for review and comment. Much more could have been added. Also, while some specific dos and don’ts, such as don’t take gifts and be careful not to attend conferences where there may be a conflict or where attendance could give rise to the appearance of one, there is no commentary. A commentary on each of the principles would have added meat to the bones by explaining why and how the conduct associated with the principle is inappropriate. And while at it, why not add some examples. Judges arriving on the job with little to no relevant experience would greatly benefit. The initiative is nonetheless a positive move.

At the ICC, in an effort to standardize the proceedings within the margin of discretion afforded to them under the Articles 64(3)(a) and 64(8)(b) of the Rome Statute and Rule 140 of the ICC Rules of Procedure and Evidence, the judges adopted the ICC Chambers Practice Manual, most recently updated at their judicial retreat of 2023. Not quite the cookbook approach of a bench book used in some domestic courts (something I have called on for years), but useful and instructive. Missing in the ICC Chambers Practice Manual are references to ethical precepts or guidance.

Perhaps inserting basic ethical refrains mirroring and supplementing the broad brush, minimally described, subjectivity prone ethics rules in a practice manual is superfluous. I disagree.

As a general principle, there is benefit in fostering uniformity on judicial ethical behavior, not to mention transparency – the indispensable ingredient for insuring confidence in and acceptance of judicial proceedings. Including concrete ethics guidelines/instructions (such as found in the Nuremberg Principles) with cogent explanations in the Chambers Practice Manual would only strengthen it. It might seem funky, even duplicative. So what. Judges invariably will consult their tailored practice (practical) manual more regularly in their day-to-day affairs than the Code of Judicial Ethics.

I’ll end with some judicial ethical issues at the various international(ized) tribunals and courts worth pondering over (none, sadly, are hypothetical). Most, if not all, can be resolved through good old fashion common sense and practical ethics. Some may have more than one answer depending on legal tradition, professional role, and practical experience. You be the judge.

• • • How ethical is it for the president of a court to attend commemoration ceremonies of an event, such as the annual commemoration in remembrance of the Srebrenica victims, when there are ongoing proceedings either at the trial or appellate level concerning those events?

• • • How ethical is it for the president of the court who is also presiding or sitting on any of those ongoing proceedings, or selecting the judges who will, to attend such commemorations?

• • • How ethical is it for the president of the court to give a speech, particularly one supporting of prosecution and touting convictions, in either of the two above scenarios?

• • • How ethical is it for a judge not to disclose his/her association or acquaintance with a witness for either party to determine whether to move for the judge’s disqualification?

• • • How ethical is it for judges not to disclose their association or acquaintance with a prevalent figure featuring in a key document likely to be relied on by the chamber?

• • • How ethical is it for a judge not to disclose to the defence that s/he is co-habiting (sharing the same living space) with the prosecutor in a case?

• • • How ethical is it for judges to comment on the evidence of a witness – heaping praises for their veracity or reliability of their expert report international(ized) tribunals – in the midst of the witness being cross-examined by a party challenging the witness’s evidence?

• • • How ethical is it for judges to sleep (extensively) on the bench while evidence is being taken?

• • • How ethical is it for a judge to extensively examine witnesses (usually to the benefit of the prosecution) in search for the truth as understood in the civil law systems, when the statutory provisions and rules of procedure explicitly rest the burden of proof on the prosecution, and when the applicable proceedings are unequivocally adversarial/party-driven?

• • • How ethical is it for the presiding judge to refuse to make rulings on evidentiary objections raised in court, thus denying the objecting party a trial record (transcript) which clearly articulates the ruling (and basis for it) for appellate purposes?

• • • How ethical is it for a chamber to postpone ruling on motions until the end of taking all of the evidence so as to insure the bell cannot be unrung and deprive the parties the opportunity to seek interlocutory appellate review?

• • • How ethical is it for a judge to hear a motion on a novel legal issue after receiving an amicus curiae brief from an organization with which the judge had a previous association and was acknowledged to have assisted with the organization’s publications on the particular legal issue in dispute?

• • • How ethical is it for a trial judge to be reluctant to apply the court’s jurisprudence and subsequently ignore instructions from the appeals chamber on the law?

• • • How ethical is it for a judge to preside over a case when s/he has previously investigated or sat in judgment of the same accused in a different court?

• • • How ethical is it for a judge to remain on the bench after admitting to having accepted cash gratuities from grateful litigants in the past?

• • • How ethical is it for a trial judge to have ex parte communications with the prosecutor even after the appeals chamber noted that such meetings could create the appearance of asymmetrical access to the judges?

• • • How ethical is it for an investigative judge in the civil law-based system to tell his/her investigators that it would be preferable to find more inculpatory than exculpatory evidence while later claiming that this comment was made in jest?

• • • How ethical is it for the presiding judge to cut off the microphone of defence counsel whenever it suited him not to have a trial record or based on whims and capriciousness?

• • • How ethical is it for the presiding judge to threaten defence counsel with disciplinary measures for supposedly investigating is a civil law-based system by bringing to the chamber’s attention information revealed to defence counsel by a court interpreter that the recorded interview was staged – the interpreter reading questions to the witness, and the witness reading prepared answers provided to him by an investigator of the investigating judges?

• • • How ethical is it for a presiding judge to severely restrict the defence in the use of leading questions during cross examination when the proceedings are adversarial/party-driven, the statutory provisions call for no such restrictions, and when other chambers in the same court afford robust use of leading questions during cross examination?

• • • How ethical is it for a judge speaking at a public event to make personal and derogatory remarks about counsel that appeared before him?

• • • How ethical is it for a judge to continually assert that the mode of liability of joint criminal enterprises (JCE) is beyond doubt customary international law, and then upon retirement reveal in a text that it was not customary international law, but convenient and suitable?

• • • How ethical is it for a judge to sit on an international tribunal while also holding a government or judicial position in his/her domestic jurisdiction where certain policy directives may limit the judge’s impartiality and independence?

• • • How ethical is it for appellate judges to assail lower court judges and accuse them of grave error, judicial malpractice, and willfully intending to circumvent the application of the law when they themselves knew of the lower court judges’ course of action prior to it being executed and were in a position to intervene, and when they subsequently failed to issue any coherent binding decision remedying any of the claimed grave errors?

• • • How ethical is it for a judge to privately circulate an email to friends wherein that judge calls into question the motives of his fellow judges in deciding on a case while also insinuating that the burden of proof should be on the accused?

• • • How ethical is it for judges to attack other judges in public decisions accusing them of subverting the ends of justice by doing nothing other than properly using their discretion in correctly applying procedural modalities?

For more on judicial ethics, here are some links to previous posts:

• • Judges’ questioning: are all questions fair game?
  • ICC Judges Yield to the Experts’ Recommendations in Amending the Code of Judicial Ethics: a welcomed but modest tinkering to an otherwise impressionistic code of conduct
  • Kosovo Specialist Chambers – Part 7: The Code of Judicial Ethics
  • Eighth and Final Installment: JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS
  • Seventh Installment: JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS
  • Sixth Installment: JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS
  • Fifth Installment: JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS
  • Fourth Installment: JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS
  • Third Installment: JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS
  • Second Installment: JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS
  • JUDICIAL ETHICS IN THE INTERNATIONAL TRIBUNALS: Drawn from Michael G. Karnavas’s lecture at the ADC-ICTY’s 12th Defence Symposium
  • A Snowy December Night in The Hague

About Author

Michael G. Karnavas

Michael G. Karnavas is an American trained lawyer. He is licensed in Alaska and Massachusetts and is qualified to appear before the various International tribunals, including the International Criminal Court (ICC). Residing and practicing primarily in The Hague, he is recognized as an expert in international criminal defence, including pre-trial, trial, and appellate advocacy.

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Author: Michael G. Karnavas

Michael G. Karnavas is an American trained lawyer. He is licensed in Alaska and Massachusetts and is qualified to appear before the various International tribunals, including the International Criminal Court (ICC). Residing and practicing primarily in The Hague, he is recognized as an expert in international criminal defence, including pre-trial, trial, and appellate advocacy. View all posts by Michael G. Karnavas