The ICTR convicted [JURIST report] former Rwandan army chief Augustin Bizimungu and three others last week. Last December, the ICTR sentenced [JURIST report] former Rwandan Armed Forces lieutenant Ildephonse Hategekimana to life imprisonment after convicting him on charges of genocide and crimes against humanity. The court found Hategekimana guilty of three counts of genocide stemming from his involvement in the 1994 Rwandan genocide, specifically in the massacre of civilian Tutsis in the Rwandan town of Butare. Last month, the ICTR removed US lawyer and JURIST Forum [website] contributor Peter Erlinder [professional profile; JURIST news archive] from his position as an ICTR defense lawyer. The appeals chamber said the dismissal was due to Erlinder's failure to appear at a tribunal and cited Rule 46 of the ICTR Rules of Procedure and Evidence [text] which allows the court impose sanctions for lawyer's misconduct. Erlinder argues [JURIST op-ed] the dismissal was part of a wider history of institutional bias that has helped the Rwandan government label him and other defense counsel "genocide deniers" subject to official threats of arrest and even death.