On November 20, 2014, the European Court of Human Rights (the Court) ruled [3] in Jaloud v. the Netherlands that the Netherlands violated the European Convention of Human Rights [4] (the Convention) by failing to properly investigate Mr. Jaloud’s shooting by a member of the Dutch military in Iraq.  According to the press release [5], the Netherlands violated Article 2 (right to life – procedural obligations) by failing to address “certain aspects . . . of the proportionality of the force used” along with not taking “appropriate steps . . . to reduce the risk of [the shooter] colluding with other witnesses” before his questioning.  Additionally, “the pathologist’s report was extremely brief, lacked detail and did not include any pictures [and] fragments of metal identified as bullet fragments taken from [Mr.] Jaloud’s body . . . had subsequently been lost in unknown circumstances.”  The Court held that even though the Dutch military was present in Iraq under British oversight, “the Netherlands was not divested of its jurisdiction solely because it had accepted the operational control of a United Kingdom officer.”