# Example — auditing user-supplied documents

Two worked audits.

## Example A — Taylor head-of-state immunity miscited

### The document

A draft article footnote reads:

> "In the Taylor Trial Judgement of 2012, the SCSL held that head-of-state immunity does not bar prosecution for international crimes."

### The audit

Two errors:

1. **Wrong decision.** The head-of-state immunity holding is from the **31 May 2004 Decision on Immunity from Jurisdiction** (Appeals Chamber, Case No. SCSL-03-01-I) — issued in the early stages of the proceedings against Taylor, when he was still a sitting head of State of Liberia. The Trial Judgement of 18 May 2012 ruled on the merits (conviction on all 11 counts) but did not revisit the immunity question, which had already been decided eight years earlier.

2. **Wrong Chamber.** The 2004 decision was issued by the **Appeals Chamber** (deciding a preliminary motion). The Trial Judgement was issued by Trial Chamber II.

**Suggested redraft:**

> "In its Decision on Immunity from Jurisdiction of 31 May 2004 (Case No. SCSL-03-01-I), the Appeals Chamber of the SCSL rejected Charles Taylor's challenge to its jurisdiction on grounds of head-of-state immunity, relying on Statute Art. 6(2) and on customary international law authorising prosecution of heads of State for international crimes."

## Example B — AFRC, CDF and RUF cases conflated

### The document

A draft brief states:

> "The SCSL's principal trial was the Sesay case, in which the AFRC defendants were convicted of war crimes."

### The audit

A characteristic Sierra Leone-case confusion (Trap 1):

- **Sesay, Kallon, and Gbao** were the **RUF** defendants — Case No. SCSL-04-15. The RUF is the Revolutionary United Front (the principal insurgency).
- The **AFRC** (Armed Forces Revolutionary Council) defendants were **Brima, Kamara, and Kanu** — Case No. SCSL-04-16.
- These were **separate cases** before separate Trial Chambers.

Additionally, the SCSL had no single "principal trial" — the four cases (Taylor, AFRC, CDF, RUF) were the four substantive prosecutions, with Taylor as the most globally prominent.

**Suggested redraft:**

> "The SCSL prosecuted four principal cases: the AFRC case against Brima, Kamara, and Kanu (Case No. SCSL-04-16, Trial Judgement 20 June 2007); the CDF case against Norman, Fofana, and Kondewa (Case No. SCSL-04-14, Trial Judgement 2 August 2007); the RUF case against Sesay, Kallon, and Gbao (Case No. SCSL-04-15, Trial Judgement 2 March 2009); and the Taylor case (Case No. SCSL-03-01, Trial Judgement 18 May 2012)."

## The common thread

The audit task in each case is **identification** — distinguishing the four principal cases, the Trial / Appeals procedural postures, and the specific decisions on which contested holdings rest. Step 0 catches the most common errors.