 In 1474, in the trial of Peter von Hagenbach by an ad hoc tribunal of the Holy Roman Empire, the first known "international" recognition of commanders' obligations to act lawfully occurred.Hagenbach offered the defense that he was just following orders, but this defense was rejected and he was convicted of war crimes and beheaded.Specifically, Hagenbach was put on trial for atrocities committed under his command but not by him directly, during the occupation of Breisach.