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The Just War Tradition provides part of the philosophical foundation for the modern lawof war and has considered both jus ad bellum and jus in bello. The Just War Tradition developedcriteria or principles that have provided the foundation for modern jus ad bellum rules. 105Similarly, law of war treaties that provide jus in bello rules, such as the 1949 GenevaConventions, are also rooted in the Just War Tradition. The Just War Tradition remains relevantfor decisions to employ U.S. military forces and in warfighting. 1061.6.5 Rules of Engagement (ROE). Rules of engagement (ROE) have been defined as“[d]irectives issued by competent military authority that delineate the circumstances andlimitations under which United States forces will initiate and/or continue combat engagementwith other forces encountered.” 107 ROE are used by States to tailor the rules for the use of forceto the circumstances of a particular operation. 108ROE reflect legal, policy, and operational considerations, and are consistent with theinternational law obligations of the United States, including the law of war. 109 ROE may restrictand other Scholastic thinkers developed the Scholastic just-war doctrine. This doctrine reached its mature form bythe time of the writings of Vitoria and Suarez in the sixteenth and seventeenth centuries. Various Protestantmoralists and secular writers dealt with just-war issues during the Reformation, but by the eighteenth century justwardoctrine was becoming a curiosity that was not taken seriously. It remained for the twentieth century reactionagainst total war to spark renewed studies in the just-war tradition.”).105 Refer to § 1.11.1 (Jus ad Bellum Criteria).106 See, e.g., Barack Obama, Remarks on Accepting the Nobel Peace Prize in Oslo, Dec. 10, 2009, 2009-II PUBLICPAPERS OF THE PRESIDENTS 1799 (“And over time, as codes of law sought to control violence within groups, so didphilosophers and clerics and statesmen seek to regulate the destructive power of war. The concept of a just waremerged, suggesting that war is justified only when certain conditions were met: if it is waged as a last resort or inself-defense; if the force used is proportional; and if, whenever possible, civilians are spared from violence.”);George H. W. Bush, Remarks at the Annual Convention of the National Religious Broadcasters, Jan. 28, 1991,1991-I PUBLIC PAPERS OF THE PRESIDENTS 70 (“Nowhere is this more true than in the Persian Gulf where -- despiteprotestations of Saddam Hussein -- it is not Iraq against the United States, it’s the regime of Saddam Hussein againstthe rest of the world. Saddam tried to cast this conflict as a religious war, but it has nothing to do with religion perse. It has, on the other hand, everything to do with what religion embodies: good versus evil, right versus wrong,human dignity and freedom versus tyranny and oppression. The war in the Gulf is not a Christian war, a Jewishwar, or a Moslem war; it is a just war. And it is a war with which good will prevail.”).107 JOINT PUBLICATION 1-04, Legal Support to Military Operations, GL-3 (Aug. 17, 2011) (“rules of engagement.Directives issued by competent military authority that delineate the circumstances and limitations under whichUnited States forces will initiate and/or continue combat engagement with other forces encountered. Also calledROE.”).108 For example, Juan Carlos Gomez, Twenty-First-Century Challenges: The Use of Military Forces to CombatCriminal Threats, 88 INTERNATIONAL LAW STUDIES 279, 285-86 (2012) (“There must be clear, understandable rulesprovided to military forces on the circumstances under which force may be used and the type and degree of thatforce. This is dependent on the mission assigned to the forces. In Colombia, two differently colored cards are used.A blue card is used when the military unit is engaged in a law enforcement mission. The rules on the blue card arebased on HRL. They provide for the use of force only when no other option is available to accomplish the missionand in self-defense of the person and others. The red card is used in operations against military objectives. Thesecards are based on IHL and permit the offensive use of force, including lethal force if demanded by militarynecessity.”).109 J. Fred Buzhardt, DoD General Counsel, Letter to Senator Edward Kennedy, Sept. 22, 1972, reprinted in 67 AJIL124 (1973) (“With reference to your inquiry concerning the rules of engagement governing American militaryactivity in Indochina, you are advised that rules of engagement are directives issued by competent military authority26

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