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|Crimes Against Humanity During the Gulf War: A Hyperlinked Pathfinder Research Tool (22 June 1998)|
III. BOOK REVIEW
This is a unique expandable and perpetual legal research pathfinder. The work expands through Internet hyperlinks which replace references and citations and enables the reader to link directly to source data in order to verify facts. Claims are confirmed instantly. Additionally, it is hyperlinked to searchable sites at law libraries and online databases that are continually updated. This creates a vehicle for continuing the original research that is, at the users discretion, updatable, self-sustaining and perpetual.
This pathfinder identifies selected sources that assist in the investigation of United States war crimes against the citizens of Iraq. While this is not an exhaustive compilation of human rights information sources, it does focus on specific war crimes committed during Operation Desert Storm and on the relevant law. My research revealed an abundance of works, primarily law review and journal articles dedicated to a call for action against Saddam Hussein for his war crimes. These range from genocide against the Kurds to the use of hostages as human shields, SCUD missile attacks against the citizens of Israel and Saudi Arabia, the invasion and pillaging of Kuwait, the use of chemical weapons and more. My research revealed little in the legal literature describing the plight of the Iraqi people. Therefore, the goal of this pathfinder is not to express outrage over a dictator's behavior, but to lead to a path to justice for the noncombatant victims of the U.S. action in the Gulf.Return to Table of Contents
After defining the task just stated in the introduction, a preliminary Internet search on Yahoo located several book sources. I used the keywords "war crimes in Desert Storm," "human rights," "war crimes," and "U.S. war crimes against Iraq." These led to several books about the injustices endured by Iraqi civilians due to the combat of United States and Coalition Forces during Desert Storm. A lengthy Westlaw natural language search first for caselaw, then for law review and journal articles, turned up almost no directly related cases but many articles. Almost all of the articles call for the enforcement of the rule of law as it relates to the war crimes of the Iraqi leader, Saddam Hussein. He has accumulated a list of crimes against humanity that goes far beyond the scope of this pathfinder. The cases are generally either appeals of convictions for desertions based on the action in the Gulf not being a declared war, or cases concerning some other war, war crime, or war criminal. The books describe a call for the indictment of a former president and his top administration officials on a 19 point war crime complaint brought by a former U.S. Attorney General. These works depict violations of international treaty sections and incidences of specific war crimes. A legal analysis of the crimes was published in two of the books used for this pathfinder. I examined many Internet sites to confirm the claims in these books. These sites indeed verified that the 19 point claim was made in 1991. Additionally, they describe a subsequent 10 point criminal claim by the same former United States Attorney General, which was made on November 14,1996. These more recent charges claim that as a direct consequence of the economic blockade and sanctions against the people of Iraq since August 6, 1990, 1.5 million deaths have occurred, including 750,000 children under five years of age. This claim charges not only U.S., but also British and U.N. leaders.
The Internet helped me locate a new related law, The War Crimes Act Of 1996. Interestingly, 18 USC § 2401 (renumbered to 18 USC § 2441) prohibits criminal acts in wartime anywhere by any member of the armed forces. This becomes more relevant when reviewing the Internet web pages that assert the view that the Gulf War is ongoing. The Boston Committe on the Middle East and the Iraq Action Coalition contend that current U.S. policy has a severe adverse effect on Iraq's civilian population. This raises several questions of law. (1) If a president and governmental officials named in the original criminal complaint were war criminals in 1991, and the "war" continues, are they included with those named in the 1996 complaint in violation of 18 USC § 2441 (in addition to the Geneva Conventions etc.)? (2) Does the War Crimes Act of 1996 establish criminal liability for the Commander In Chief, The Secretary of Defense, and the Commanding Generals if they committed war crimes? (3) Does a relation-back doctrine apply to 18 USC § 2441 since the war "endures" through the implementation of a United States policy that arises from Desert Storm and continues to kill Iraqi citizens? (4) If the United States policy is in violation of existing law (18 USC § 2441) what is the result? (5) Would a policy change be required as a matter of law?Return to Table of Contents
III. BOOK REVIEW
1. The Fire This Time - U.S. War Crimes in the Gulf (ISBN # 1-56025-047-X)
This was the most comprehensive account of the devastation upon the infrastructure, property and civilian population of Iraq. There is a detailed legal analysis by former U.S. Attorney General Ramsey Clark as to the specific war crimes committed against the people of Iraq. He observed first-hand the violations of law and magnitude of the destruction resulting from the war. Chapter 9, entitled "Crimes Against Peace, War Crimes, and Crimes Against Humanity," itemizes the violations of international law. These crimes are acts in violation of the Charter of the United Nations (Articles I & II); Part IV, Section 22 of the Hague Conventions of 1899, revised in 1907, Charter of the Nuremberg Tribunal 1950, No. 82 and Protocol I of 1977 Addition to the Geneva Conventions of 1949 (Part IV Articles 48, 51, 55, 56 & 57). Chapter 3, entitled "War Crimes Against Iraq's Civilian Population" describes the targeting of infrastructure and life support systems, the bombing of cities and highways, and the devastation of the Amariyah Civilian Bomb Shelter. Explicit crime victim accounts and interviews depict the tragedies on a deeply human level. The legal analysis is presented by one most qualified to do a legal analysis, the former United States Attorney General, Ramsey Clark. Michael Ratner, former director of the Center for Constitutional Rights and past president of the National Lawyer's Guild presents an additional legal analysis of International law and war crimes. The book has extensive references and led me to many other related printed and Internet legal research sources.
2. War Crimes - A Report on United States War Crimes Against Iraq (ISBN # 0-944624-15-4)
The Commission of Inquiry for the International War Crimes Tribunal has compiled material into a book with explicit photos. Most of the information in the book was originally presented at the first hearings of the Commission of Inquiry in New York City on May 11, 1991. Over 1,000 people attended hearings, which featured international organizations presenting evidence and testimony. Hearings took place in 28 U.S. cities and 15 countries. Ramsey Clark outlines a 19-point indictment of the precise crimes committed.
Part 1 details the 19 crimes, the legal basis for the claims, and describes the specifics of the offenses with data relating to the events. This includes 113,000 civilian deaths, 60% of which were children, the destruction of 10 to 20 thousand homes/apartments; and other explicit charges relating to injuries and property damage. Part 2 deals with international law and war crimes, and reiterates the legal analysis presented in The Fire This Time. Part 3 depicts comprehensive testimony and evidence. Appendix C describes the reports from International Tribunals in Belgium, Turkey, and East Asia. The "Highway of Death" is discussed in the book, and can be viewed through links to other Federation of American Scientists sites.
3. ACCESS Guide to the Persian Gulf Crisis
The report was printed during the third week of the hostilities. The Allies had already flown 30,000 sorties against Iraq. While opinion polls reflected support for President Bush's decision, there was a growth of demonstrations throughout the U.S. to protest the war and to end combat. This guide is a 64-page brief, split into sections on the following subjects: (1) Background of the Crisis; (2) Issues for Discussion; (3) Resources (including: reports & studies, databases, and government speakers bureaus); and 4. Guide to Organizations. The Guide to Organizations provides almost twenty pages of groups with an interest in the Crisis, their position and purpose, and ways to contact them. These lists led to finding present day Internet sites for my research. Some organizations listed include:
4. Bibliography on Peace, Security, and International Conflict Management -United States Institute of Peace 1993
This is a joint publication by the Jeannette Rankin Library Program of the United States Institute of Peace and others (from many universities and libraries). The collaborative effort resulted in a compilation of approximately one hundred titles, covering the best works in print (as of 1993) on Peace, Security, and Conflict Management. The bibliography is intended for college-educated readers who are not specialists in these areas. On page 39, the Title Index is particularly useful in focussing the reader's attention on the most relevant works. There are 9 sections to the project, including sections on: International Law and International Order (page 20), Human Rights and Ethnic and Religious Conflicts (page 15), and International Organizations and Trans-nationalism (listings # 38-73). For background, I will list several from this group that are useful in gaining a basic understanding of associated issues but do not directly address particular war crimes committed during Operation Desert Storm.
The United States Institute for Peace is an independent, nonpartisan federal institution created and funded by Congress to promote the peaceful resolution of international conflict. The board of directors consists of distinguished professors from top universities, U.S. ambassadors and other experts.
A. The Structure and Process of International Law: Essays in Legal Philosophy, Doctrine, and Theory (ISBN # 9024728827, R. St. J. Macdonald and Douglas M. Johnston, ed.) This is a collection of articles written by "lawyer-diplomats" from around the world intended to further the development of International law.
B. On the Law of Nations (ISBN # 0674635752, Daniel Patrick Moynihan) This book provides a history and analysis of international law in the decision-making process of nations. Moynihan describes the decreasing tendency of U.S. policy to adhere to international law over the past 20 years.
C. The International Organizations and World Order Dictionary (ISBN # 0874365724, Sheikh Rustum Ali) This is a dictionary containing about 300 entries intended to assist in understanding the terms used in treaties, and by international organizations.
5. The United Nations and the Iraq-Kuwait Conflict 1990-1996 (ISBN # 92-1-100596-5)
This book is a complete account of the chronology of the conflict, lists and text of documents, and an introduction by Boutros Boutros-Ghali, Secretary-General of the United Nations. Section two, starting on page 119 is the most factual chronology of events available and is needed for a complete understanding of the Gulf War.
6. The Kuwait Crisis: Basic Documents (ISBN # 0521463084)
The Research Center for International Law at the University of Cambridge (U.K.), compiled and published a collection of documents that relate to the legal aspects of the crisis. The most recent document in the collection is from December 10, 1990. The most pertinent sections are chapters four (The Implementations of Sanctions) and five (Naval and Aerial Interdiction). There is also a Historical Background section, (chapter one) which begins at 1898 and proceeds up until the OPEC meeting of 1990.
7. Hidden Casualties - Environmental, Health and Political Consequences of the Persian Gulf War (ISBN # 1-55643-163-5, Saul Bloom, John Miller, James Warner, and Philippa Winkler, ed.)
This book focuses on the crimes relating to the environment during the Gulf War. Chapter 8 has an interview with Francis Boyle, Professor of International Law at the University of Illinois. This interview occurred (August 1991) while he was serving as advisor to Congressman Henry Gonzales on an impeachment resolution against President Bush. The section addresses the environmental damage and the war crimes by the United States against the people of Iraq and the environment. The violations of the United Nations Charter (Article 2 and Article 33) are discussed, as are the violations of the Geneva Protocols, and the Hague Regulations of 1907. There are many useful chapters, but in this section there is an independent source supporting the claims made by former United States Attorney General, Ramsey Clark. The foreword is by Representative Nancy Pelosi who provided a part of the official debate on the floor of Congress about the large-scale environmental disaster and the Gulf War three days before the War began (January 12, 1991).
8. The International Court of Justice (ISBN # 90-411-0221-3)
This book covers the activities of the International Court of Justice from 1946 through to 1996. The most relevant section is chapter 6, which is entitled Matters of Jurisdiction and Procedure. It is a comprehensive information source about the Court.
The full text of the Constitution is available online.
Part two of the 1997 edition is a complete listing of mutilateral treaties and other agreements. Page 370 of this book has the Geneva Conventions and the Rules of Warfare.
This is a report by Amnesty International from September, 1993. The report discusses the Iraqi Human Rights violations of torture, causing the "disappearance" of detainees, extra-judicial executions and other serious war crimes. The report has several sections with the most relevant, "Human Rights Violations During The Occupation," starts on page five. Appendix A and B are details reported to Amnesty International and photos of 140 Kuwaitis and others believed to be held in secret detention in Iraq. Amnesty International has a posting of "Disappearances" online.
12. The Iraqi Invasion of Kuwait: American Reflections
This report/book has eyewitness accounts for the first 62 pages after an introductory comment by Ambassador W. Nathaniel Howell. Pages 63-78 contain the Report on Iraqi War Crimes (Desert Shield/Desert Storm) Unclassified Version, from the War Crimes Documentation Center, Office of the Judge Advocate General Headquarters, Department of The Army; Washington D.C. 20310, January 8, 1992 (released February 1993). The document is the result of a U.S. Army 199th and 208th Judge Advocate detachment deployed to investigate allegations and collect evidence. The 208th started the War Crimes Documentation Center. The U.S. Naval Reserve Judge Advocates and the Army National Guard Judge Advocates, along with 15 Kuwaiti volunteers, broadened this research. This is a fascinating document to read as it describes graphically many of the war crimes committed by the Iraqis. One section outlines the law and specific incident, showing how the facts fit the violation of law. The presentation is much like a shortened form of a memorandum of law. At the end of the report is a list of videotapes, slides and prints along with the file number and brief description of the war crime committed. Some of these are things such as, torture, unjustified killings, the listing of torture centers, and more. One of these JAG detachments (199th) is at MacDill Air Force Base. FL. Other evidence remains at the Joint Combat Camera Centers (JCCC).
The War Crimes Documentation Center (WCDC) pictorial Library has images in still video, motion video, and still photo (slide or print). This library is located at WCDC File 151 Vol. 1, 2, and 3. Procedures for retrieving specific images can be located at WCDC File154, which include comment sheets.
A chronology of events of Desert Storm is available online.Return to Table of Contents
IV. INTERNET RESEARCH METHODOLOGY
I began my Internet research effort after reading Ramsey Clark's books (described in my book review). A random search using online search engines returns too many and sometimes unrelated sites. Therefore, I needed to learn to limit my research, to return search results pertaining to the topic at hand. For example, an Alta Vista search using the keyword phrase "human rights" located 32,914,690 items at the time I commenced my Internet research. Using Alta Vista's "refine" feature narrowed the sites returned to about 4,589,087 by adding "US human rights violations against Iraq". The use of the Internet is much more efficient if you know precisely what you are looking for. Since a topic search expands by each word added, one must be specific.
(1) The purpose of my first Internet search was to locate all the documents (Treaties, U.S. Constitution and Conventions) that were mentioned in The Fire This Time and War Crimes. I started at the Nova Southeastern University Law School Library's page. From the Library page click on Internet Legal Research, and then to Legal Research by Subject (FindLaw). From the list of topics on FindLaw, I selected International Law. Continue this process to reach Laws and Government Resources and chose the topics : (1) U.S. Constitution; (2) United Nations Charter; (3) Database of Treaties; selecting each, only one at a time. After finishing with reading, printing or downloading (copying the file) of the U.S. Constitution go on to the United Nations Charter and do the same (read, print or download it). After completing items 1 & 2 we can focus our attention on the Database of Treaties. This will lead us to Human Rights and then select Geneva Convention. Select Geneva Conventions I, II, III, & IV, each one at a time and then; read, print or download as needed. At the bottom of the list there is a title: Other Human Rights Collections---select, Project DIANA. DIANA is a searchable international human rights database that accesses sections of the human rights libraries of Yale and the University of Minnesota (and other universities). The project is dedicated to the memory of Diana Vincent-Daviss, who was a legal scholar and the Deputy Director of the Orville H. Schell, Jr. Center for International Human Rights at Yale Law School. Select DIANA at the University of Minnesota and search by key word for Hague Convention. Then, repeat the process for Nuremberg Tribunal. After finding and printing or downloading these additional items go back to the itemized list of the 19-point criminal complaint detailed in The Fire This Time and War Crimes by Ramsey Clark. The documents collected via the Internet were the Treaties, and International Agreements that were breached in violation of International Law, which were mentioned above. All of these: The U.N. Charter, The U.S. Constitution, The Geneva Conventions, The Hague Conventions and The Nuremberg Tribunal were claimed by former United States Attorney General, Ramsey Clark to have been violated. To perform a thorough job of objective evaluation we need to review these documents, and we are able to retrieve them quickly by the steps outlined above, by using the Internet.
(2) The next major Internet search was a direct result of my newfound awareness of The War Crimes Act of 1996. It seemed important to read and evaluate the new law to see how it related to the claims mentioned earlier. I started my search as previously described, but I will briefly outline all the steps below. I started at the NSU Law Library home page and then clicked on Internet Legal Research. Then select Federal Research, which leads to House of Representatives Law Library. There are two routes of interest: Treaties and International law; and Search the U.S. Code. Select the latter, which appears on the left of the screen. This brings up Statutes and after selecting, leads you to U.S. Code (via Cornell). Next, select "a form which permits you to look up specific sections." Scroll down to Title 18 and click on search, then type: War Crimes Act of 1996. Review the material that appears and then click on update. Click on the Library of Congress Database and then search for the 104th and 105th Congress by clicking on word/phrase, then point at and click on search. Type: war crimes, and click on search, and 37 items will appear. Browse these items by scrolling down to review for relevance since there is a brief description of each item. Look at item numbers 4, 6, and 12 each, one at a time in separate searches. Click on 4, and then click on All Bill and Status Information (except Bill text). Next click on Summary and Status For The 104th Congress and on this Bill (H.R.3680). Click on Public Law : 104-192 (08/21/96) Text. Click on Continue which brings up Public Law 104 -192 and read, print and download 18 USC § 2441. This Act may be cited as " War Crimes Act of 1996." Note the date (8/21/96), the legislative history and the references. Repeat this process for 6 and 12. Please note that when I did this I was unable to explore item number 12 fully. There was an incomplete section of data, and I did not pursue this further since I already found the War Crimes Act of 1996.
(3) The next Internet search I performed resulted from my earlier lengthy exploration of the hard copies of Dispatch. Dispatch is a publication of the State Department. My method of locating the online version of Dispatch is outlined below. Start at the NSU Law School Homepage and select Library. This leads to a page where you would select Internet Legal Research and then to Legal Research by Subject (FindLaw). Click on International Law, then select Government Agencies on the next page that comes up; under USA (the first major heading) click on the 4th bullet item from the top: Department of State Foreign Affairs Network (DOSFAN). This brings you to The Department of State Electronic Research Collection, and then click on Publications - Major Reports at the University of Illinois at Chicago Library. Click on Dispatch, and select from the various issues to then browse. This is much quicker than pulling the hard copies, but there is no search feature in this collection as I had hoped, so you still need to scan for the topics of interest. There are four volumes available in browser-readable HTML format. The University of Illinois site and the State Department sites both have more issues available online using the Adobe Acrobat Reader plug-in. When following this link, select "Adobe Acrobat Reader for the type of computer you are reading. This downloads the plug-in's installation software, which you must then run (double-click in Mac or Windows; "run (filename)" in DOS) to install the software. You may need to reboot your computer to enable the software.
The most relevant article from both searches (Internet and hardcopies) was an address by the U.S. Ambassador at Large for War Crimes Issues at the Carter Center in Atlanta, Georgia. David J. Scheffer, on November 13,1997, presented an address called U.S. Policy and the Proposed Permanent International Criminal Court, Vol. 8, No. 10, p.20 Dec. 1997. Once inside this Adobe Acrobat document, use the search function (binoculars) to search by author's name or title. The purpose of this court is the global protection of human rights.
There was one other excellent report by David J. Scheffer. His address was given February 24,1998, and his Title is now U.S. Ambassador at Large for War Crimes at the University of Oklahoma College of Law, Norman, Oklahoma. This report was entitled The Clear and Present Danger of War Crimes, Vol. 9, No. 2, p.19 Mch. 1998. His report was about crimes against humanity and the move to establish a permanent international criminal court to bring to justice, future perpetrators of genocide and war crimes.
There is another State Department site that relates to this pathfinder, called the Human Rights Report. This site is a Country Report on Human Rights Practices for 1997 which was released on January 30, 1998. There is a link to a press briefing by Deputy Secretary Strobe Talbot and Assistant Secretary for Democracy, Human Rights, and Labor; John Shattuck (DOSFAN).
(4) The next Internet search was to locate online access to the International Court of Justice and information concerning its procedures and jurisdiction. This search is supplemental to book number 8 described above, in the book section of this pathfinder. The NSU Law School Homepage is our starting point again. From here select the Law Library and then to Internet Legal Research and then select Legal Research by Subject (FindLaw). Click on International Law from the list that appears and then select Government Agencies. From the next page that appears, select Statute of the International Court of Justice. This brings you to the Table of Contents, and then click on Chapter III: Procedure (Articles 39-64).
I suggest going through the process at least once from the beginning since there are many related sites of interest along the way. The most useful site was Government Agencies because of a comprehensive list to browse. This is a starting point to explore the United Nations-related sites and U.S. Agencies such as the State Department, and their on-line documents and libraries.
(5) Using the last Internet address mentioned as a starting point I proceeded with an on-line search for the related treaties mentioned earlier in the Books section of this pathfinder. From the last Internet address (mentioned five lines above) select Treaty Section (OLA/Treaty) and then click on International Law and Human Rights Introduction. Please Note: Registration is required to access the United Nations Treaty Collection.
On the next the page that appears, select Treaty Section and click. This brings you to a page with four boxes and select the lower right box that says Access to Treaty Collection. This is the United Nations Treaty Collection. You must subscribe by filling out some basic information and then have free access to the treaties. Click on Go to Treaty Collection. This is probably the largest treaty collection in one place and the United Nations is a superior resource for many types of research, beyond the topic of war crimes. You assign yourself a username and password when registering. You can then search or browse for related treaties.
I also found an interesting source for "Think Tanks" worth mentioning. This was a link to RAND, Brookings Institution and others if you scroll down at the site, but these were not specifically used in this pathfinder.
1. Kenneth A. Williams, The Iraq-Kuwait Crisis: An Analysis of The Unresolved Issue of War Crimes Liability 18 Brook. J. Int'l. 385 (1992).
This article presents a complete legal analysis of the war crime liability of both the Iraqi and American leaders with probable defenses. The main focus is on the violations of Article 6-13 of the Nuremberg Tribunal Charter which followed World War II. Article 6 is discussed in detail as it relates to the acts of both leaders, and section V of this paper calls for the creation of a permanent war crimes tribunal. The paper presented the case for war crimes against Presidents Hussein and Bush and their possible legal posture.
The author is an Assistant Professor at Thurgood Marshall School of Law. There are lengthy references and notes, which are a rich resource for additional material. This law review article was retrieved as a result of a Westlaw natural language search in the section Journals and Law Reviews. The search phrase was US War Crimes Against Iraq.
2. Chris af Jochnick and Roger Normand, The Legitimation of Violence: A Critical History of The Laws of War/bin//bin/sh: ispell: command not found sh: ispell: command not found b> 35 Harv. Int'l L.J. 49 (1994).
The paper starts with a quote from (1984) by George Orwell: " Who controls the past controls the future; who controls the present controls the past." This is one of the best articles I have read. The article challenges the notion that the laws of war restrain war or humanize war. There is a historical approach to the structure of the paper with the conclusion asserting that through the law, violence has been legitimated. The reasoning is that the laws of war have facilitated rather than restrained violence in war. The reference to a Coalition's reputation for only targeting military sites is shown to be false in the sense that independent studies show about 111,000 Iraqi civilians died many of which were a result of the Allied bombing. Please note the fourth reference. Beth Osborne Daponte is a demographer with the U.S. Census Bureau who reported the number of civilian deaths. The references in this journal article are one of the best sources of documented reports and high quality useful information related to this pathfinder topic. The historical perspective gives the background needed for a complete understanding of the war and war crimes. The number of deaths of Iraqi citizens is somewhat corroborated by the numbers closely matching those reported in the books written by Ramsey Clark. The claim that the law is the facilitator of violence is an interesting view and when you finish reading the article you see the point clearly. This article was located in the same Westlaw search as the first one in this section.
There were many journal articles on war crimes that concerned conflicts other than the Gulf War. I stayed focussed on just the U.S. war crimes against the Iraqi citizens and I included peripheral information to understand the entire war situation objectively. The articles included in this section provide Gulf War-specific detail on U.S war crimes against noncombatant Iraqis. Furthermore, the quality and quantity of the references from these articles are excellent as a resource for further study.Return to Table of Contents
This Pathfinder began as a report on the U.S. War Crimes Against Iraq and evolved into an invaluable research tool because of Internet Hyperlinks. As you continue to investigate this and related topics you now have access to the world of international law with defined (Internet) starting points:
General Human Rights links to many sites can be found at:
I found credible sources itemizing the specific war crimes such as:
These were verified independently, by law reviews and book sources with particular attention to the quality of the references in those sources. Several detailed legal analyses were identified. One analysis was by a former United States Attorney General. Additional legal analyses which were identified and included were written by the foremost legal scholars working in this subject area. My research did not reveal any directly related case law. Therefore, I limited the use of Lexis and Westlaw for some primary source documents such as the United States Constitution. Searches were performed on Westlaw (natural language), Lexis, and LegalTrac, which became valuable tools to find secondary sources such as law review articles. There was an accumulation of many resources along the way, for others to continue to lead a path to justice for the noncombatant Iraqi victims of the Gulf War.
Before studying law, Barry Goodman was a Vice President of Sales & Marketing in the electro-optics industry. He has a BS, an MS, several publications in scientific journals, and a US Patent. His interests include human rights, intellectual property law, contracts, construction law, biomedical applications of lasers, environmental law and fiber-optic bio-sensors.