[Pinckney]

In warfare. A commander can be criminally liable for failing to prevent criminal actions by their subordinates. Most famously, Tomoyuki Yamashita. Or from the prosecution brief during Ernest Medina's trial:

>'When troops commit massacres and atrocities against the civilian population of occupied territory or against prisoners of war, the responsibility may rest not only with the actual perpetrators but also with the commander. Such a responsibility arises directly when the acts in question have been committed in pursuance of an order of the commander concerned. The commander is also responsible if he has actual knowledge, or should have knowledge, through reports received by h'un or through other means, that troops or other persons subject to his control are about to commit or have committed a war crime and he fails to take the necessary and reasonable steps to insure compliance with the law of war or to punish violators thereof.'