Operation Anthropoid, the mission to assassinate Reinhard Heydrich, is simultaneously seen as one of the bravest and one of the most terrible acts of Czech defiance during World War Two (WWII). The event was marked by extreme reprisals by the Nazi regime which has led to an ongoing debate over the legality and morality of the assassination. After a brief look at the scenario which led to the assassination, followed by an outline and explanation of the basic principles of the Just War doctrine, it will be demonstrated that under the circumstances, In spite of the devastating reprisals, the assassination of Reinhard Heydrich was justified.
The Czechoslovak nation was born out of the ashes of the First World War, in accordance with Section VII of the Versailles Treaty, and would virtually disappear two decades later, in the lead up to World War II. The Nazi regime exploited unrest in the Sudetenland, a majority German speaking area on the shared borders with Germany, to gain cause for invading Czechoslovakia for their industrial capacity and natural resources. The major 5 European powers, in order to attempt ‘appeasement’, passed the ‘Munich Agreement’ without consulting the fledgling State, providing Hitler with the Sudetenland. This land also contained significant Czech border military defences.
After the Munich Agreement, Nazi Germany occupied the Sudetenland. Slovakia broke away from the Czech lands, forming their own fascist government, and forming an alliance with Germany. Shortly after, in contravention of the Munich Agreement, and Article 81 of the Treaty of Versailles, Nazi Germany forced agreement with the interim President into subsuming the Czech lands into the German Reich as the ‘Protectorate of Bohemia and Moravia’. This was quite obviously not what was desired by Czech citizens, and several resistance groups formed and attempted passive and active resistance measures such as intelligence gathering and civil disobedience to indicate displeasure with the status quo. There is some evidence that resistance activities were having more effect, and increasing in number around the time of Operation Barbarossa, however, according to MacDonald, much of this resistance work was uncoordinated, and ineffective. Furthermore, the quantity of resistance activities had been exaggerated for political purposes on both sides.
For the Government in Exile, headed by Benes, it was exaggerated for favour with the Allies; on the German side, it prompted a regime change in the Protectorate, from a ‘diplomatic’ von Neurath to Reinhard Heydrich – a regime change that had deadly consequences for many, and subjugation under oppressing terror for others. After several years of exile, working with the Allies, and attempting to inspire resistance at home, Edvard Benes and Frantisek Moravec developed a mission to convince the allies that Czechoslovakia was worth saving. Two men from their small military were selected and trained for the mission in Britain, in conjunction with SOE, then were parachuted into the Protectorate on 28/29th December 1941. Their task: the assassination of the Reichsprotektor, Reinhard Heydrich.
The plan did not go smoothly, but finally, on 27th May 1942, these two men attempted to assassinate the Reichprotektor. Whilst the attack initially appeared unsuccessful, injuries sustained by Heydrich in the attack led to his death on 4th June. The reprisals were swift and severe; it is estimated that around 5000 people lost their lives, two villages, Lidice and Lezaky, were targeted, and in the case of Lidice, completely wiped off the map. These reprisals have led to an ongoing debate over the relative worth of the assassination, and whether it can be justified. The ‘Just War’ doctrine can give the tools to investigate this possibility.
Just War Doctrine
The Just War doctrine is an ethical calculus to determine the moral standing of a war, the Jus Ad Bellum, and particular conduct within that war, the Jus in Bello. It begins from the assumption that war is wrong, and from this, attempts to proscribe specifics on when, and how, a state may wage war. The requirements of Jus Ad Bellum are that the conflict is: authorised by a legitimate authority; for a ‘Just Cause’; as a ‘last resort’ when other methods have failed, or are unable to be tried; undertaken with the ‘right intention’; when the war is amenable to success; and there is proportionality between the positives and negatives. Proportionality is also a requirement of Jus in Bello, the rules of conduct within the conflict, as are the requirements to discriminate between combatants and non-combatants, conformity to law, and refrain from ‘reprisals’, a like-for-like abuse of jus in bello.
WWII was entered into with the agreements freely made between the allies, in response to the threat, and conduct of Germany. There is no suggestion of incorrect authorisation for the larger context of WWII. However, there may be some qualms about recognising the authority of ‘President’ Benes to order the Heydrich assassination. President Benes resigned his post in 1938 under pressure from Germany, and went into voluntary exile prior to the annexation of the Czech lands. He was replaced by Emil Hacha, who, following the Munich Agreement, and the secession of Slovakia, was coerced by Hitler into authorising the annexation of the remainder of the Czech lands. Hacha remained in his post, largely as a figurehead; however this would present a prima facie case against the authority of Benes.
At the outbreak of WW2, Benes sought recognition as the leader of a Czech government in exile. He managed the military actions of the Czech servicemen who had left during the takeover, as well as the negotiation of resistance activities in the Protectorate. Together with other Czechs who had escaped, Benes formed a Government-in-Exile, and sought recognition by the Allies as the continuation of legal Czech Government. With some hesitancy over legal status, Benes was recognised by France and Britain as the legal government of Czechoslovakia. Based on the recognition of his Government-in-Exile, his former status as President, and the popularity of him at home, it would seem credible that Benes was suitably authorised to conduct military action against a hostile aggressor.
Just Cause and Last Resort
If it is granted that President Benes had the requisite authority to conduct war on behalf of the Czechs, the next consideration of the Just War principles is the reason for the conflict – and further, the reason for the particular action taken. According to the Just War theory, a state may only engage in war ‘for a just cause’, which is usually limited to the resistance of aggression. This can include defence of one’s own state, that of another, or punishment for a grievous wrongdoing. Likewise, war should only be undertaken if all other possible avenues for peaceful resolution have been attempted, that is, as a last resort.
It is relatively uncontentious that WWII, on behalf of the Allies, was a war of self-defence that was only entered into after other diplomatic means had failed. The Czechs had already attempted to use defence treaties with other nations as a disincentive to the Germans. They also did not contest the Munich Agreement, even though they were not party to the negotiations. Arguably this was the most important attempt at diplomacy in the war; even the acceptance of German occupation was done with the intent to avoid mass casualties in war. However, with the German response to occupation, and the severe repercussions of any act of civil disobedience, there was little hope of any alternative to a peaceful resolution of the occupation.
The appeasement was unsuccessful; following the annexation of the Sudetenland, Germany put pressure on Slovakia to secede, and then contravened the Munich Agreement, as well as the Treaty of Versailles, in occupying Czech lands. Furthermore, the actions taken by both Reichsprotektors, but in particular Heydrich, not only killed and detained Czechs, but also placed the remainder constantly under threat. Therefore, it is clear to see that the Czechs had just cause, in defending their state from an aggressor. More arguable is their just cause to punish, as in recent literature, the right to punish is considered eroded. As noted by both Moravec and MacDonald, the primary service the Czechs were providing to the Allies was intelligence; they had largely steered clear of placing their people at greater risk than they already were – the decision of the Czech Government in Exile was clearly the last option available, and not a desired one.
The proper intention, for the resort to war, is the aim to prosecute the states just cause. According to the Just War theory, ‘[u]lterior’ or ‘irrational’ motives are inadmissible as motivation. To determine whether the Czech decision to engage in assassination for the proper intention, it is necessary to consider the writing of Frantisek Moravec. In his memoirs, he tries to give an account of the Government in Exile’s reasoning for the assassination. He tells of two primary reasons: to highlight meaningful resistance to the Nazi regime, and to re-spark resistance efforts. Both of these reasons aim at prosecution of a just cause – that of defending what was left of the Czech state from a hostile force. However, these intentions can also be otherwise construed, particularly in the choice of assassinating Heydrich; ‘meaningful resistance’ in this context can be considered a purely political or punitive motive, just as ‘re-sparking the resistance’ can be seen as undertaking to intentionally risk harm to non-combatants. This is an inherent difficulty in determining intent, and is difficult to resolve, since it ‘is largely based on perception and context’, and those using assassination as a policy tool ‘will deny they were motivated by politics’. However, it should be noted that the presence of multiple motives does not necessarily delegitimise an attempt at self-defence. Nor does it necessarily preclude defensive actions based on the probability of success.
Probability of Success
Just War theory aims to prevent needless deaths in service to a lost cause, and so under this theory, a state should only resort to war if the probability of success is high. This would seem to indicate that the Czech leadership in exile may have ‘entered’ the war unjustly. Nevertheless, there is some moral scope to consider even ‘hopeless’ actions to be undertaken in pursuit of justice, just as there are cases where inaction could be considered immoral, as the ‘success’ criterion fails to take into consideration the nature of the threat. In some cases, the threat will justify an attempt that may not have immediate, measurable success. In the case of WWII, against an aggressor with significantly greater power, the probability of success in war was quite low for the Czech nation, indeed, but for errors made, this point could have allowed the Nazi regime to overtake Western Europe.
Jus Ad Bellum
Proportionality must be considered at two stages in the Just War doctrine; as a feature of Jus Ad Bellum, and that of Jus in Bello. Under Jus Ad Bellum, proportionality requires that the positive outcomes must be weighed against the expected negative outcomes, which includes foreseeable consequences to non-combatants. The war must only take place if the benefits are proportional – the positives should exceed the negatives.
The main contention against the assassination is that the consequences outweighed the benefits. Any attempt to justify the assassination will have to deal with the question of value: Was the life of one man, Heydrich, worth the lives of some 5000 civilians? It is difficult to suggest, in considering the proportionality rule, that reprisals were an unforeseen side effect; resistance groups in Bohemia/Moravia had attempted to have the assassination called off due to what they saw as likely horrific consequences. While it was clear to Benes and Moravec that reprisals would be severe, the answer must be yes. They could not have foreseen the events that happened, nor can anyone see what may have happened in absence of the assassination.
While it is indeed possible that some of those targeted in reprisal may not have died, it is difficult to argue that if the assassination not taken place, then the majority would not have been targeted under some other auspice. This is especially relevant noting that the figures suggest around 3500 of the some- 5000 people targeted in reprisal were Jews. As Gerwarth explains, persecution of Jewish people in the Czech lands ‘had begun immediately after the German invasion’. With an estimated 80,000 Jewish people killed from the Bohemia/Moravia area alone, it is difficult to claim the 3,000 Jews killed in reprisal would have escaped Nazi plans. Likewise, with the infiltration of the underground in the Czech lands, every day brought the resistance members the chance to be discovered and either killed or detained.
Based on his previous positions and his actions while Reichsprotektor of Bohemia/Moravia, there was little doubt his influence and tactics would not continue – wherever he was positioned. Heydrich’s task was not diplomatic, but one of combat, aimed at ridding the Protectorate of resistance, and increasing output for war efforts. Had he lived, it is entirely possible that his next position would be in France, which would have severely curtailed resistance there. Furthermore, noting his developing rapport with Hitler, he may have played a significantly greater role in the development of the war, and the efficiency of the holocaust. Even granting that they died because of the assassination, which is not entirely uncontentious, the blame still cannot be morally ascribed to the Government-in-Exile in toto. As Hauner has put it,
… those who argue that sparing Heydrich could have saved thousands of lives must also face the fact that every day of his service to the Third Reich meant the further perfection of the Nazi killing machine and the a more ruthlessly efficient genocide. By killing one of Hitler’s ablest lieutenants, the brutal regime and its collaborators were shaken, and the occupied peoples of Europe given hope.
There was a war going on: militaries were being decimated to defend their lands, and liberate those already forcibly taken; men, women and children were being killed or sent to concentration camps for arbitrary reasons; and even in areas under German rule, there were people risking, and losing their lives to resist the Nazi regime. While being unsuccessful in its aim to re-spark the resistance, they did prosecute their main goal – meaningful resistance to an aggressor. It removed not only the ‘local tyrant’, but also someone Hitler considered ‘irreplaceable’. The assassination further enabled the continuity of the Czechoslovak state post-war, and removed the ‘stigma’ of dishonourable collaboration.
Jus in Bello
Proportionality and Discrimination (Non-Combatant Immunity)
Proportionality refers to the means, and degree to which a combatant may use force. Under Jus in Bello, those in combat must only use only sufficient force to achieve their aims. It would be unjust, therefore, to use nuclear weapons to terrorise a nation into unconditional surrender. The assassins who killed Heydrich clearly fulfilled the requirements of proportionality for Jus in Bello; they killed only who they were sent for, using the minimum force required to complete their task, and did not kill another combatant, even when under threat. The ‘assassins’ took great pains to minimise casualties amongst non-combatants; only targeting Heydrich, and firing warning shots into the air to avoid civilian incursion into the area. This also shows their action to be just, under the requirement to discriminate between combatants and non-combatants.
The legality of assassination is usually the most difficult to overcome, since it appears to depend on how you present it. There is sometimes a distinction made between assassination, seen as killing someone, particularly a civilian, for political motives, and ‘targeted killing’, defined as the elimination of a military threat. Hauner even considers labelling the assassination of Heydrich as ‘state-sponsored terrorism’, which is aligned closer to how the ‘assassins’ themselves saw their actions. However, there is not such a clear demarcation between these titles. Heydrich, for example, was clearly: a public figure in the Protectorate killed in part for political purposes, i.e. regime change; a combatant killed in part for defence from aggression and prevention of further oppression; and was a tyrant killed by the ‘resistance’ for his tyranny.
However the assassination is labelled, it is necessary to consider international law of the time. The Hague Conventions, Section IV, Article 23 states that ‘[i]n addition to the prohibitions provided by special Conventions, it is especially forbidden […] [t]o kill or wound treacherously individuals belonging to the hostile nation or army’. Since combatants are traditionally marked by visual indications of allegiance, such as uniforms or insignia, and the assassins were in civilian clothes, this has led some to believe there is a prima facie case for the illegality of the Heydrich assassination; ‘treachery’ is usually seen as akin to giving an enemy cause to believe you were not a threat and since the assassins were not wearing uniforms, they gave the illusion of being civilians. However, as noted by Parks, the prevailing conditions in WWII often required the reliance on local resistance members, not uniformed military, and following the Heydrich case, this deficiency was recognised, and prompted a number of states to clarify their ‘law of war manuals’ to ensure that activity by resistance movements was not precluded. Furthermore, as a legal combatant, Heydrich had no claim to immunity from attack, and as noted by Spaight, surprise is not a form of treachery.
This final requirement is based around the idea that ‘an eye for an eye leaves us both blind’. For an act to be a ‘reprisal’ in this context, it must be a violation of jus in bello in retaliation for another’s previous violation. This rule acknowledges that tit-for-tat abuses of law do not lead to positive, peaceful outcomes. This is also a common issue with the Heydrich case; assassination, being viewed with its negative connotations, is seen as an abuse of law in retaliation – ‘because he did it first’. However, as seen in the previous section, assassination is a contentious description in itself, and that the Heydrich assassination could, in our modern terms, take on either one of the two other descriptions. If we grant the outcome of the previous section, that it was not an unlawful act, it is clear that while we may consider the act ill-advised, it was certainly not a reprisal in the Just War sense.
While acknowledging the terrible loss of life which came as retribution for Heydrich’s death, It has been shown, using the Just War doctrine, and relevant historical data that the assassination was justified through the satisfaction of the requirements of Jus Ad Bellum and Jus in Bello. While it did not achieve all its aims, it was a brave, perhaps ill-advised attempt to remove a tyrant, to stand up against an aggressive regime, and to ensure the continuity of a state that was hard won.
Bikár, František. “Czech Senator Warns against Hatred, Racism, Nationalism, Xenophobia.” Romea.cz (2013). http://www.romea.cz/en/news/czech/czech-senator-warns-against-hatred-racism-nationalism-xenophobia.
Brownlee, Kimberley. “Civil Disobedience.” In The Stanford Encyclopedia of Philosophy, edited by Edward N. Zalta. http://plato.stanford.edu/archives/spr2010/entries/civil-disobedience.
Burian, Michal , Aleš Knížek, Jiří Rajlich, and Eduard Stehlík. Assassination: Operation Anthropoid 1941-1942. Prague: Ministry of Defence of the Czech Republic – Military Information and Service Agency (AVIS), 2002. http://www.army.cz/images/id_7001_8000/7419/assassination-en.pdf.
Canestaro, Nathan. “American Law and Policy on Assassinations of Foreign Leaders: The Practicality of Maintaining the Status Quo.” Boston College International and Comparative Law Review 26, no. 1 (2003): 1 – 34.
Geary, Dick. “The Nazi State and Society.” In Hitler and Nazism, edited by Dick Geary, 37-61, 1993.
Gerwarth, Robert. Hitlers Hangman: The Life of Heydrich. London: Yale University Press, 2011.
Gould, Harry D. “What Happened to Punishment in the Just War Tradition?”. Chap. 4 In Ethics, Authority, and War: Non-State Actors and the Just War Tradition, edited by Eric A. Heinze and Brent J. Steele, 73 – 100. New York: Palgrave Macmillan, 2009.
Gross, Michael L. “Killing the Innocent: The Dilemma of Terrorism.” Chap. 8 In Moral Dilemmas of Modern War: Torture, Assassination, and Blackmail in an Age of Asymmetric Conflict, 178 – 204. Cambridge: Cambridge University Press, 2009.
Hauner, Milan. “Terrorism and Heroism: The Assassination of Reinhard Heydrich.” World Policy Journal 24, no. 2 (Summer 2007): 85-89.
Hays Parks, W. “Executive Order 12333 and Assassination.” edited by Office of the Judge Advocate General of the Army. Washington DC: Department of the Army, 2002 (Reproduction).
Knoepfler, Stephen “Dead or Alive: The Future of U.S. Assassination Policy under a Just War Tradition.” New York University Journal of Law & Liberty 5, no. 457 (“?
Lillian Goldman Law Library. “Laws of War: Laws and Customs of War on Land (Hague Iv); October 18, 1907.” http://avalon.law.yale.edu/20th_century/hague04.asp#art23.
———. “The Versailles Treaty June 28, 1919: Part III.” http://avalon.law.yale.edu/imt/partiii.asp#art81.
MacDonald, Callum. The Killing of SS Obergruppenführer Reinhard Heydrich. 1st ed. New York: Da Capo Press, 1998. 1989.
Meisels, Tamar. “Targeting Terror.” [In English]. Social Theory and Practice 30, no. 3 (2004): 297-326.
Moravec, F. Master of Spies: The Memoirs of General Frantisek Moravec. Bodley Head, 1975.
Orend, Brian. “War.” In The Stanford Encyclopedia of Philosophy, edited by Edward N. Zalta, 2009. http://plato.stanford.edu/archives/fall2008/entries/war.
Statman, Daniel. “The Morality of Assassination: A Response to Gross.” Political Studies 51, no. 4 (2003): 775-79.
Statman, Daniel “On the Success Condition for Legitimate Self‐Defense.” Ethics 118, no. 4 (2008): 659-86.
 Callum MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 1st ed. (New York: Da Capo Press, 1998), 45, 49.
 Robert Gerwarth, Hitlers Hangman: The Life of Heydrich (London: Yale University Press, 2011), 218.
 Lillian Goldman Law Library, “The Versailles Treaty June 28, 1919: Part III”.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 64.
 The Killing of SS Obergruppenführer Reinhard Heydrich, 108.
 Gerwarth, Hitlers Hangman: The Life of Heydrich, 221.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 78.
 The Killing of SS Obergruppenführer Reinhard Heydrich, 62; Gerwarth, Hitlers Hangman: The Life of Heydrich, 219.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 107-18.
 Michal Burian et al., Assassination: Operation Anthropoid 1941-1942, (Prague: Ministry of Defence of the Czech Republic – Military Information and Service Agency (AVIS), 2002), http://www.army.cz/images/id_7001_8000/7419/assassination-en.pdf. 44; MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 128; Interestingly, the testimony in F. Moravec, Master of Spies: The Memoirs of General Frantisek Moravec (Bodley Head, 1975), 202. claims a scheduled departure in ‘late April’. With several sources corroborating the December date, the given month is considered to be a mistake.
 Brian Orend, “War,” ed. Edward N. Zalta, Fall 2008 ed., The Stanford Encyclopedia of Philosophy (2009), http://plato.stanford.edu/archives/fall2008/entries/war. In using the basic outline found here, I have merged 3 duties into one, so as to cover them all in a single discussion of ‘legality’.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 102-03.
 Orend, “War.”
 Even considering the justifiable concerns over the severity of sanctions in the Treaty of Versailles post-WWI, as discussed in Lillian Goldman Law Library, “The Versailles Treaty June 28, 1919: Part III”.
 Harry D. Gould, “What Happened to Punishment in the Just War Tradition?,” in Ethics, Authority, and War: Non-State Actors and the Just War Tradition, ed. Eric A. Heinze and Brent J. Steele (New York: Palgrave Macmillan, 2009), 73.
 Moravec, Master of Spies: The Memoirs of General Frantisek Moravec, 197; MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 71, 92-98; see also Milan Hauner, “Terrorism and Heroism: The Assassination of Reinhard Heydrich,” World Policy Journal 24, no. 2 (2007): 86. Hauner claims that Heydrich was the turning point in this policy.
 Orend, “War.”
 Moravec, Master of Spies: The Memoirs of General Frantisek Moravec, 196.
 Nathan Canestaro, “American Law and Policy on Assassinations of Foreign Leaders: The Practicality of Maintaining the Status Quo,” Boston College International and Comparative Law Review 26, no. 1 (2003): 11.
 Tamar Meisels, “Targeting Terror,” Social Theory and Practice 30, no. 3 (2004): 306-07.
 Daniel Statman, “On the Success Condition for Legitimate Self‐Defense,” Ethics 118, no. 4 (2008): 666; Kimberley Brownlee, “Civil Disobedience,” ed. Edward N. Zalta, Spring 2010 ed., The Stanford Encyclopedia of Philosophy, http://plato.stanford.edu/archives/spr2010/entries/civil-disobedience.
 Daniel Statman, “The Morality of Assassination: A Response to Gross,” Political Studies 51, no. 4 (2003): 778.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 156.
 Gerwarth, Hitlers Hangman: The Life of Heydrich, 220.
 František Bikár, “Czech Senator Warns against Hatred, Racism, Nationalism, Xenophobia,” Romea.cz(2013), http://www.romea.cz/en/news/czech/czech-senator-warns-against-hatred-racism-nationalism-xenophobia.
 This is not to suggest the loss of Jewish life is unimportant, merely that noting the anti-Semitism at the heart of Nazi Germany intended the expulsion/extermination of the entire Jewish population, that these people would have been targeted even had the assassination not provided the opportunity to purge them.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 113; see also Gerwarth, Hitlers Hangman: The Life of Heydrich, 227.
 Hitlers Hangman: The Life of Heydrich, 226.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 165-66.
 Meisels, “Targeting Terror,” 318, 21-22.
 Hauner, “Terrorism and Heroism: The Assassination of Reinhard Heydrich,” 89.
 Resistance movements were dealt with harshly when found. Dick Geary, “The Nazi State and Society,” in Hitler and Nazism, ed. Dick Geary (1993), 40-42.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 182.
 The Killing of SS Obergruppenführer Reinhard Heydrich, 200-04; see also Statman, “On the Success Condition for Legitimate Self‐Defense,” 667.
 MacDonald, The Killing of SS Obergruppenführer Reinhard Heydrich, 172.
 Stephen Knoepfler, “Dead or Alive: The Future of U.S. Assassination Policy under a Just War Tradition,” New York University Journal of Law & Liberty 5, no. 457: 467.
 Hauner, “Terrorism and Heroism: The Assassination of Reinhard Heydrich.”
 Burian et al., Assassination: Operation Anthropoid 1941-1942.
 Lillian Goldman Law Library, “Laws of War: Laws and Customs of War on Land (Hague Iv); October 18, 1907,” http://avalon.law.yale.edu/20th_century/hague04.asp#art23.
 W Hays Parks, “Executive Order 12333 and Assassination,” ed. Office of the Judge Advocate General of the Army, Memorandum of Law (Washington DC: Department of the Army, 2002 (Reproduction)), 5.
 “Executive Order 12333 and Assassination,” ed. Office of the Judge Advocate General of the Army, Memorandum of Law (Washington DC: Department of the Army, 2002 (Reproduction)), 3.
 as cited in Canestaro, “American Law and Policy on Assassinations of Foreign Leaders: The Practicality of Maintaining the Status Quo.”
 Orend, “War.”
 Michael L. Gross, “Killing the Innocent: The Dilemma of Terrorism,” in Moral Dilemmas of Modern War: Torture, Assassination, and Blackmail in an Age of Asymmetric Conflict (Cambridge: Cambridge University Press, 2009), 191-95.
 Meisels, “Targeting Terror,” 306-07.