The United States incorporated the two Hague Conventions on "command responsibility" into federal law through the precedent set by the United States Supreme Court (called the "Yamashita standard") in the case of Imperial Japanese Army General Tomoyuki Yamashita. He was prosecuted in 1945 for atrocities committed by troops under his command in the Philippines, in the Pacific Theater during World War II. Yamashita was charged with "unlawfully disregarding and failing to discharge his duty as a commander to control the acts of members of his command by permitting them to commit war crimes."