Missouri Law Review Volume 24 Issue 1 January 1959 Article 7 1959 International Law on Use of Enemy Uniforms As a Stratagem and the Acquittal in the Skorzeny Case Maximilian Koessler Follow this and additional works at: https://scholarship.law.missouri.edu/mlr Part of the Law Commons Recommended Citation Maximilian Koessler, International Law on Use of Enemy Uniforms As a Stratagem and the Acquittal in the Skorzeny Case, 24 MO. L. REV. (1959) Available at: https://scholarship.law.missouri.edu/mlr/vol24/iss1/7 This Article is brought to you for free and open access by the Law Journals at University of Missouri School of Law Scholarship Repository. It has been accepted for inclusion in Missouri Law Review by an authorized editor of University of Missouri School of Law Scholarship Repository. For more information, please contact
[email protected]. Koessler: Koessler: International Law on Use of Enemy Uniforms As a Stratagem INTERNATIONAL LAW ON USE OF ENEMY UNIFORMS AS A STRATAGEM AND THE ACQUITTAL IN THE SKORZENY CASE MlAxnaLmiA KoEssLER* I. INTRODUCTION Prior to the trial, by an American military commission entitled "Military Government Court,"' of Otto Skorzeny and his codefendants,2 which trial took place in Dachau between August 18 and September 8, 1947, and ended with an acquittal of all the defendants, the international law on legitimacy or illegitimacy of the use of enemy uniforms as a stratagem was not settled in so far as use outside open combat was con- cerned, as will be later on discussed at some length. One writer has expressed the view that the outcome of that trial supports the view "that such deception is permissible if not done in battle."8 However, this is not necessarily so.