According to legal scholar Lawrence Douglas, in spite of serious missteps along the way, the German verdict brought the case "to a worthy and just conclusion". After the conviction, Demjanjuk was released pending appeal. He lived at a German nursing home in Bad Feilnbach, where he died on 17 March 2012. Having died before a final judgment on his appeal could be issued, under German law, Demjanjuk remains technically innocent. In January 2020, a photograph album by Sobibor guard Johann Niemann was made public; some historians have suggested that a guard who appears in two photos may be Demjanjuk.