On December 1, 2014, the Appeals Chamber of the International Criminal Court (the Court) affirmed the Trial Chamber’s decision in Prosecutor v. Thomas Lubanga Dyilo to convict [3] Mr. Lubanga of the “enlistment, conscription, and use in hostilities of children under the age of fifteen” as well as his fourteen-year sentence [4].  According to the press release [5], Mr. Lubanga appealed on the grounds that “the proceedings were unfair” and that he was not personally responsible for the individual criminal acts of which he was convicted.  The Court affirmed “the Trial Chamber's approach that a co-perpetrator must make an essential contribution and does not need to personally and directly commit the crime” and noted the Trial Chamber’s broad discretion in deciding an appropriate sentence, holding that “the sentence was not disproportionate to the gravity of the crimes and reflected Mr. Lubanga's culpability for the crimes for which he was convicted.”