ke civil courts, however, a person can be convicted in a commission trial by a two-thirds majority of the commissioners. A unanimous verdict of seven members is necessary to sentence the accused to death. The procedures do not provide for appeals from a guilty verdict to civilian judges. They do, however, call for "reviews" of a verdict by a three-member panel selected by the Secretary of Defense. No verdict will be final until approved by the President of the United States or, if the President authorizes, the Secretary of Defense.
             Having some knowledge of what military tribunals are, it is appropriate to consider how the United States has used military tribunals throughout its history. These tribunals were often called military commissions and have been used in connection with formally declared wars as well as other military conflicts, such as the Civil War and conflicts with Indian tribes. They have been used for three basic purposes: to try enemy belligerents for violations of the law of war; to administer justice in territory occupie
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