APPENDIX

NAZI EUTHANASIA TRIALS

Given Adolf Hitler’s twin obsessions with neo-classical aesthetics and waging wars of aggression to acquire, and then racially cleanse, territory in the east, it should not be surprising that the mentally and physically handicapped were among the Nazis’ first victims.¹ Two years before the Final Solution, they had created a system of government-run killing centers (the so-called “T-4 program”) to murder the disabled through poison gas, a technology later transferred, along with the personnel who administered it, to murder the European Jews in the death camps of Poland. By the end of the war, between 250 and 300,000 disabled patients had been killed in Operation T-4.

This essay will explore postwar efforts to prosecute Nazi doctors, nurses, public health officials, and medical personnel for their participation in Operation T-4. As we will see, T-4 crimes were among the first of the Nazis’ homicidal actions to face judicial punishment. Their prosecution would continue, fitfully and unevenly, for decades after the war’s end. Because the vast bulk of these proceedings occurred in the immediate postwar era (1945–50), we will focus on this critical period before turning to the handful of more recent trials and criminal investigations.

1. ALLIED PROSECUTION OF NAZI EUTHANASIA CRIMES (1945–47) THE US ARMY’S HADAMAR TRIAL

The earliest Nazi euthanasia trial was held by the US Army in Wiesbaden, Germany, from October 8 to 15, 1945. Its object was the health care staff of the mental hospital located in the town of Hadamar near Limburg (province of Hesse-Nassau). In 1940 Hadamar became a replacement killing center for Grafeneck, which was closed along with its sister killing center Brandenburg in December 1940. In the next nine months the T-4 medical staff at Hadamar gassed at least 10,000 mentally disabled German patients. The killing process ceased for a year after Hitler ordered a stop to Operation T-4 in August 1941 but resumed its deadly work in August 1942, using overdoses of narcotics as the new killing agent. During this second phase, both mentally disabled German youngsters and so-called “Mischlinge” (or half-Jewish) children were killed at Hadamar. So, too, were concentration camp prisoners targeted as part of the “14f13” operation, designed to relieve overcrowding in the rapidly growing concentration camps by sending ill prisoners to euthanasia centers for liquidation. Finally, by late in the war Hadamar staff were killing by lethal injections hundreds of Polish and Russian forced laborers ill with tuberculosis. Their murders were the focus of the US Army’s Hadamar trial.

Figure x.1. The Hitler “Euthanasia” Decree, signed in October 1941 but backdated to September 1, 1941. Source: Wiki Commons (public domain)

Authority to prosecute the Hadamar medical staff was based on a Joint Chiefs of Staff directive called “1023/10,” which assigned authority for war crimes trials to military theater commanders. Responsibility for holding the trials was vested in the Office of Military Government for Germany (OMGUS) and the Deputy Judge Advocate for War Crimes, European Command. Direct authorization for trials like the Hadamar proceeding was issued in late August 1945. It provided the basis for indicting and prosecuting Germans suspected of war crimes. The trials would be conducted by “military commissions,” which would be free to fashion procedural rules derived from those governing General Courts-Martial.

In their approach to “euthanasia” crimes committed at Hadamar, US military lawyers assumed that the domestic T-4 program was legal by virtue of Hitler’s September 1, 1939, decree to Philip Bouhler and Karl Brandt, authorizing them to organize the adult euthanasia program. On this theory, the only killings that violated international law at Hadamar were those involving the sick Polish and Russian slave laborers, and even then, to be justiciable under international law, it would have to be proven that the victims were not mentally ill at the time of their killing. If they were mentally ill, then the Hitler authorization as a domestic German law would have rendered their killing lawful. Hence, the Americans charged the Hadamar staff solely with the illegal destruction of mentally competent foreign laborers.

There were seven defendants indicted at the Hadamar trial. The leading accused was Alfons Klein, the director, followed by Adolf Wahlmann, the chief doctor; Heinrich Ruoff, the head male nurse; Karl Willig, the Ward male nurse; Irmgard Huber, the head female nurse; Philip Blum, the hospital’s cemetery attendant; and Adolph Merkel, the registrar and bookkeeper. All of the defendants had participated to some degree in the killings of the victims. While conceding their involvement in the foreign workers’ deaths, the defendants contended that they in good faith believed their actions were lawful under the Hitler decree of September 1, 1939. For this reason, therefore, they lacked the intent to commit a criminal act and should be acquitted. Remarkably, the prosecution objected to any introduction of evidence bearing on Hadamar’s role in the larger T-4 campaign to annihilate the disabled, an objection upheld by the military commission judges. The stolid refusal of the judges to consider the broader context of mass murder at Hadamar undermines confidence in their discernment or fairness. The issue was not whether the defendants had participated in killing, which they did; the issue was that the defendants acted within a political and social forcefield willfully ignored by the prosecution and largely suppressed by the military commission. This notwithstanding, the military commission agreed with the prosecution and, after a one-week trial, found all the defendants guilty of murder in violation of the Geneva Conventions and the Laws of War. It sentenced Klein, Ruoff, and Willig to death and the other defendants to hard labor for terms varying from life to 25 years.

The pattern of ignoring or misrepresenting Nazi euthanasia established in the Hadamar trial would continue in the prosecution of Nazi doctors at Nuremberg.

The US Medical Case at Nuremberg

Coincidentally, just as the Hadamar “euthanasia” trial was among the first of the Army’s military commission trials, the opening case in the USA’s “subsequent” trials at Nuremberg also touched on “euthanasia,” however slightly. The stimulus to pursuing German doctors for medical crimes arose during the International Military Tribunal trial of the 21 major war criminals. During the prosecution’s case against Hermann Göring, information came to light of Luftwaffe physicians’ participation in macabre medical experiments carried out on concentration camp prisoners. In mid-1946 an American investigative team under James McHaney collected evidence on the leaders of the SS medical service. The bonanza of incriminating data gathered by McHaney’s team, along with the availability of potential defendants among former Nazi medical officials in American and British custody, persuaded the head of the US “subsequent” trial program, Telford Taylor, to start the subsequent proceedings with a trial of twenty-three Nazi doctors and bureaucrats.

The “Doctors Trial” was only incidentally about Nazi euthanasia. Its focus was on the grisly medical experiments conducted in concentration camps like Dachau and at the SS sanatorium of Hohenlychen. Only four of the twenty-three accused were charged with euthanasia crimes: Karl Brandt, Hitler’s personal physician and the Reich Commissioner for Health and Sanitation; Viktor Brack, the chief of Section II of the Führer’s Chancellery; Waldemar Hoven, a SS physician at the Buchenwald camp; and Kurt Blome, the Deputy Reich Health Leader. Euthanasia was charged against these four men as a crime against humanity under Control Council Law #10 (the legal basis of the US subsequent trials). Although their involvement in medical experiments was the real gravamen of the trial, the defendants defended their participation in euthanasia as motivated by compassion for the suffering patient. The prosecution strove to refute their defense with evidence of the crass utilitarian philosophy underlying the T-4 program.

In its verdict convicting Brandt, Brack, and Hoven of crimes against humanity (Blome was acquitted), the tribunal agreed with the prosecution’s theory that Nazi euthanasia was intended to remove economically unproductive people (“useless eaters”) in order to free up resources for the German army. The court, in other words, endorsed the view that aggressive warfare and imperialist expansion were the causes of the T-4 program. By emphasizing the calloused military advantages to be gained through the murders of the disabled, the judges at the Doctors Trial overlooked—much like their counterparts at the Army’s Hadamar trial—the much more expansive and complex etiology of Nazi euthanasia, a program driven not just by a violent utilitarianism but by the racial and eugenic policies of the Third Reich. The three convicted men were hanged at Landsberg am Lech prison in 1948.

2. GERMAN PROSECUTION OF NAZI EUTHANASIA CRIMES IMMEDIATE POSTWAR ERA (1945–50)

The primacy of euthanasia and medical crimes in Allied courts after the war would also characterize the early German trials devoted to Nazi atrocities. In the case of the Germans, however, the reason why euthanasia crimes were among the first wave of prosecutions had much to do with limitations imposed on the German judiciary by the Allies. Allied Control Council Law #10 (decreed in December 1945) allowed zonal commanders to entrust the prosecution of Nazi crimes to German courts when the victims were either Germans or stateless persons. Obviously, crimes against peace and war crimes, by their very definition, involved non-German victims and thus lay outside the jurisdiction of German courts. Certain kinds of crimes against humanity, on the other hand, fell within German jurisdiction because they involved attacks on German nationals. This was particularly so in the events of the Reich Night of Broken Glass pogrom (Nov. 1938) and the T-4 program targeting German disabled patients. The euthanasia cases, like nearly all of the T-4 crimes pursued in German courts, charged their accused with homicide under the German penal code, sec. 211, which defined a murderer as “any person who kills for pleasure, for sexual gratification, out of greed or otherwise base motives, treacherously or cruelly or by means that pose a danger to the public or in order to facilitate or to cover up another offence.”

The earliest German euthanasia trial, and one representative of the rigor with which T-4 killings were treated by German courts immediately after the war, was the 1946 prosecution by a Berlin district court in the Soviet zone of two health care staff from the Obrawalde mental hospital near Meseritz (Pomerania), physician Hilde Wernicke and nurse Helene Wieczorek. Wernicke had given orders to administer lethal injections and Wieczorek had obeyed them. The two women were convicted of murder and sentenced to death in March 1946. The judges found that their participation in euthanasia satisfied the murder statute’s elements of “cruelty” (by inflicting severe physical or mental pain on the victims), “treacherous” (by exploiting the defenselessness of the victims), and “base motives,” a term relating to the grossly unethical character of the killings.

Other German courts dealing with T-4 crimes followed much the same interpretation of homicide as the Obrawalde court had applied. In a pair of trials held in December 1946 and January 1947, a Frankfurt district court convicted health care personnel implicated in euthanasia killings in Hessen of murder. The staff of the Hadamar institution, some of whom had already been tried by US military commission in October 1945, were charged with murder and found guilty in March 1947. The will to convict and punish was typical of these early euthanasia trials. Defenses like superior orders or mistake of law were typically brushed aside and the accused convicted as perpetrators of murder.

A fateful exception to this willingness to convict euthanasia killers as perpetrators began to emerge in criminal trials by the late 1940s. Under German criminal law, once a defendant was convicted of murder, it also had to be determined whether s/he was a perpetrator or an accomplice. If the killer carried out the crime without personally benefiting from it, s/he was an accomplice; if s/he either subjectively endorsed the killing or controlled its circumstances, then the offender was a perpetrator, meaning that s/he could be punished more severely. Up until the late 1940s, German courts routinely rejected this “subjective” theory and convicted direct killers as perpetrators. By 1948 a harbinger of change appeared in the previously mentioned Hadamar trial, in which the doctors were convicted as perpetrators but the nursing staff were only considered accomplices on the grounds that they had “[acted] weakly and without will.” Rather than being sentenced to death for murder (the customary sentence at the time for a person convicted as a perpetrator), the nurses were given prison terms of three to eight years.

In the aftermath of the Hadamar case, German courts began to apply the subjective theory to euthanasia doctors, classifying them as accomplices to homicide rather than perpetrators. Increased resort to subjective theory moved in concert with the legal doctrine of necessity to reduce the punishment of proven killers and, in some instances, to justify their acquittals entirely. This occurred in the October 1948 trial of Drs. Karl Todt and Adolf Thiel, charged for their roles in aiding the transfer of disabled patients from the Scheuern mental hospital (Hessen-Naussau) to the T-4 killing center at Hadamar. The defendants raised a “collision of duties” defense, claiming they had remained at their posts instead of resigning in order to sabotage the euthanasia program from within. A Koblenz district court accepted this defense of necessity and acquitted both men, holding that their actions had been justified. It was significant for the judges that the defendants had saved the lives of 20% of the patients at the cost of minimally contributing to the transfer of others. This was the first German trial in which euthanasia defendants were acquitted based on a necessity defense.

Other German courts followed the Koblenz district court down the path of necessity. In a November 1948 trial of physicians and public health officials in the Rhine province medical system, the defendants were charged, as in the Scheuern case, with transferring patients based on prepared lists to T-4 hospitals where they were murdered. The defendants raised a necessity defense, arguing like Todt and Thiel that they had remained in their jobs with the aim of sabotaging the program. As in the Todt and Thiel prosecution, too, a Düsseldorf district court acquitted the defendants based on evidence of their resistance, much or all of it provided by the defendants’ medical colleagues.

In other euthanasia trials in German courts, evidence of alleged sabotage was even more meager. This was true of the trial of Dr. Alfred Leu in Cologne in the early 1950s. Leu, a doctor at the Sachsenberg mental hospital near Schwerin, was charged with murder for his role as head of Sachsenberg’s pediatrics ward, in which disabled children were killed with overdoses of veronal and luminal. Leu raised a necessity defense, arguing that resigning from his post would merely have resulted in his replacement by a zealous Nazi. The Cologne district court accepted this defense and acquitted Leu.

The outcome of Alfred Leu’s case is notable because of the clear evidence of wrongdoing ignored or minimized by the judges. These included well-attested statements by Leu during the war that endorsed the euthanasia program, identifying him on the spectrum of German doctors as a firm proponent of Operation T-4. Other witnesses claimed to have seen Leu authorize the murder of patients by means of drug overdoses. The evidentiary record showed that top officials associated with T-4 regarded Leu as a “great guy” acting “entirely in accordance with the wishes” of Berlin. In short, the district court’s verdict was in sharp contradistinction to such evidence, suggesting that the court wanted from the outset to acquit Leu despite strong indications of his guilt.

The Quiescent 1950s

The Leu case is significant because it represents a dissipation of German interest in prosecuting Nazi crimes by the early 1950s. The statistics are emphatic on this point: while the numbers of investigations into Nazi crimes by the West Germans were fairly high in 1950 (2,495), they had declined to 467 by 1952 and 183 in 1954. Similarly, whereas German courts had convicted 1,819 Nazis in 1948, the figures fall off a steep cliff thereafter − 809 in 1950, 259 in 1951, 191 in 1952, 123 in 1953, 44 in 1954. In 1955 the West Germans had convicted only 21 Nazi defendants and in 1956 a mere 23. For much of the 1950s, euthanasia prosecutions were a painted ship on this painted sea of Nazi trials.

The kickstart to renewed engagement with Nazi crimes (including euthanasia) was the 1958 trial in the German city of Ulm of former German policemen implicated in the murders of Jews along the German-Lithuanian border during the summer of 1941. The Ulm trial, which resulted in murder convictions of the defendants and multi-year prison sentences, led to the formation of a new government body devoted exclusively to the investigation of Nazi crimes. Headquartered in Ludwigsburg, the new agency was called the “Central Office of the State Judicial Administrations for the Investigation of National Socialist Violent Crimes.” The labors of the Central Office would bear fruit in the coming years in the form of block-buster criminal trials of ex-Nazis; the Belzec, Sobibor, Treblinka, Chelmno, Auschwitz, and Majdanek trials were all outgrowths of Central Office investigations.

Renewed Prosecutions of T-4 Crimes in West Germany

One manifestation of this revitalized interest in Nazi crimes was the headline-grabbing indictment of prominent T-4 officials Werner Heyde (alias Fritz Sawade), Gerhard Bohne, Friedrich Tillmann, and Hans Hefelmann in 1962. Heyde/Sawade was a psychiatrist profoundly implicated at multiple levels in Nazi medical crimes, including as a chief reviewer (Obergutachter) of patients designated for killing. Bohne was an ex-SS Hauptsturmführer involved in the creation and administration of Operation T-4. Tillman, like Bohne, was the head of one of the T-4 offices. Hefelmann, as chief of Office IIb in the Führer’s Chancellery, was involved in implementing both the adult and the children’s euthanasia programs. Scheduled to begin in front of a lay assessors court in Limburg on February 16, 1964, the trial was abruptly short-circuited when Tillmann and Heyde both committed suicide (Tillmann six days before trial, Heyde five days). Bohne, released from pre-trial detention against all recommended precautions, fled the country to Argentina. Extradited back to West Germany in 1966 to stand trial, Bohne was declared medically unable to participate in the preliminary investigation, leading to its indefinite postponement. Delays in Hefelmann’s prosecution ended when he was declared medically unfit to stand trial in 1972. Consequently, none of these T-4 potentates was ever held legally accountable for his numerous crimes.

Fiasco followed on fiasco for other attempts to prosecute T-4 operatives in the 1960s. In 1965 the Hessian attorney general Fritz Bauer filed indictments against three former T-4 doctors implicated in gassing patients at the killing centers Grafeneck, Brandenburg, and Bernburg: Aquilin Ullrich, Heinrich Bunke, and Klaus Endruweit. Their acquittal on a technicality in their first trial in May 1967 was overturned by the German Supreme Court, which reinstated prosecution. The case had to be abandoned in 1970 when the defendants were deemed medically unfit to stand trial. Prosecution was suspended until 1986, when it was resumed after a journalist revealed the three doctors were working full-time in their medical practices. The trial resulted in the conviction of Ullrich and Bunke for aiding and abetting murder; they were sentenced to a four-year prison sentence. Efforts to revive the case against Endruweit proved thornier as the determination of his medical unfitness continued until 1991. At this time, the charges he faced were finally dismissed.

For Kurt Borm, a T-4 doctor who under the alias “Dr. Storm” gassed some 6,652 disabled patients at Sonnenstein and Bernburg, prosecution for mass murder ended in acquittal in June 1972. According to the district court of Frankfurt, Borm had lacked “consciousness of illegality” due to the “pitiful condition” of the “zombie-like, degraded lives” whose misery he abbreviated. Innocent of aiding and abetting murder, the only other charge he faced, manslaughter, was barred by the statute of limitations. The thousand-fold killer walked out of the courtroom scot-free.

This mixed record of alternating successes and defeats in the prosecution of Nazi euthanasia continued with the 1967 trial of T-4 operatives Gerhard Bohne, Dietrich Allers, Reinhold Vorberg, and Gustav Kaufmann. After some delay due to Vorberg’s flight to Spain, aided by the suspicious actions of a circuit court judge, the trial ended with Allers’ and Vorberg’s conviction for aiding and abetting murder. Bohne and Kaufmann, on the other hand, were declared medically unfit to stand trial. They were never punished for their crimes.

Checkered outcomes were the norm in other euthanasia prosecutions of the late 1960s. Three T-4 officials, Georg Renno, Hans-Joachim Becker, and Friedrich Lorent, were tried in 1969. In 1970 Becker and Lorent were convicted and sentenced to a prison term while Renno was declared medically unfit to stand trial. The designation of his unfitness remains controversial to this day. The upshot was that Renno escaped prosecution for his numerous crimes, which included work as a gassing doctor at the Hartheim euthanasia center and as an expert evaluator (Gutachter) to determine patients’ eligibility for killing. The theme of head-scratching attestations of medical unfitness continued with the indictment of Horst Schumann, director of the Grafeneck and Sonnenstein euthanasia centers. If these assignments were not incriminating enough, Schumann also participated in the selection of concentration camp prisoners for liquidation in the 14f13 program (designed to reduce overcrowding in concentration camps) and in efforts to sterilize Jewish women at Auschwitz by means of X-rays. To avoid capture Schumann had fled Germany to Egypt in 1955, winding up in Ghana in 1959. Extradited to Germany in 1966, his trial began in Frankfurt in 1970. Like Renno, Bohne, Kaufmann, and many other medical criminals, Schumann’s trial was aborted after he was declared medically unfit to stand trial.

Fritz Bauer’s Effort to Prosecute the German Judiciary for Its Complicity in Euthanasia

From the standpoint of justice, the only thing worse than a failed prosecution for terrible crimes is a trial that never takes place at all. This was the outcome of Fritz Bauer’s 1965 attempt to prosecute members of the German judiciary for collaborating with the T-4 program. Bauer’s initiative was breathtakingly audacious. Where the dominant focus of euthanasia prosecutions in West Germany hitherto had been on health care professionals − doctors, nurses, public health officials, T-4 operatives − Bauer thrust his spearpoint into the German legal profession and its complicity in euthanasia.

The basis of Bauer’s preliminary investigation was an April 1941 meeting of the presidents of the regional appellate courts (OLG) and the attorneys-general with Franz Schlegelberger, the state secretary in the Reich Ministry of Justice. The meeting was held in the “Haus der Flieger” (House of the Aviators) in Berlin. The assembled jurists were addressed not only by Schlegelberger but by the leading lights of the T-4 program: Viktor Brack, who displayed the Hitler euthanasia decree of September 1, 1939, and Werner Heyde. The purpose of the meeting was to instruct the leaders of the German criminal justice system to forward all investigative documents and arrest warrants pertaining to T-4 to the Reich Ministry of Justice. Further, they were told to quash all legal proceedings in their court systems that were based on alleged euthanasia crimes. As Bauer noted in his summary of the meeting, “None of those present protested. No one expressed reservations.” According to Bauer, this lack of protest from the very people entrusted with enforcing the law encouraged T-4 officials to continue their murders of the disabled without fear of judicial intervention. Had they protested, Bauer asserted, the conference participants might have stopped the mass murder in its tracks in the spring of 1941. Their failure to do so made them complicitous in murder.

Thirty of the jurists who attended the meeting were still alive and available for prosecution in 1965. Bauer’s investigation targeted 29 of them. Franz Schlegelberger himself lived in Flensburg at the time. This notwithstanding, a German Supreme Court ruling in February 1966 in effect immunized Schlegelberger from further prosecution (on the assumption that he had already been punished for his medical crimes in the American Doctors Trial, where he had been convicted of crimes against humanity). As a consequence the Limburg district court dismissed the case against him in December 1966. Before Bauer’s unexpected death on July 1, 1968, he witnessed the collapse of his case against several of the jurists listed in his original report. In 1970 the attorney general in Frankfurt dismissed proceedings against the remaining jurists, claiming a lack of evidence on their part to aid and abet euthanasia. (The dismissal on these grounds, as some scholars have argued, flies in the face of German law, which specifically criminalizes encouragement of a crime as “psychological aiding and abetting”). With the final withdrawal of its case, the attorney general’s office brought a definitive end to Bauer’s endeavor.

3. CONCLUSION

In sum, the euthanasia trials in the Federal Republic sentenced seven defendants to death, of whom two were executed, and 29 to prison sentences ranging from four months to life in prison. Most of the defendants were doctors, nurses, hospital aides, and administrative personnel. Forty-nine cases ended in acquittals or dismissals of the charges.

It should be emphasized that, after the initial burst of hardnosed judgments right after the war, T-4 defendants faced their courts as accomplices of murder, not perpetrators. Beginning in the late 1940s, the German judiciary chose to view the acts of euthanasia killers and accomplices solely through the lens of complicity, a decision that virtually guaranteed leniency. Moreover, the gradual reintegration of compromised judges into the postwar German judiciary, particularly in the west, meant that former Nazis presided over many of these trials. The extraordinary and counterfactual leniency of some of these verdicts may have arisen from the judges’ sympathy with the accused.

Whether we are considering American approaches to euthanasia in the Hadamar and Doctors trial or the German T-4 prosecutions, the degree of official misrepresentation is striking. The Americans consistently misstated the aims of Nazi euthanasia by conflating them entirely with aggressive war-making while the German courts ascribed dubious, if not completely spurious, motives to some T-4 killers, crediting them with unproven sabotage actions that belied their real support for murdering the disabled (as in the case of Alfred Leu) or denying criminal action despite countervailing evidence (as in the ill-fated jurists case initiated by Fritz Bauer).

The euthanasia trials and their outcomes demonstrate the refusal of human beings to confront the truth about their crimes or the motives behind them. At the end we are left with the somber realization that, in all the vast world of human experience, man’s greatest mystery remains himself and the fathomless depths of his own heart.

SELECTED BIBLIOGRAPHY

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1 This essay was originally published in the issue “Useless Lives: The Nazi ‘Euthanasia’ Program,” Minority Reports (December 2021): 199–214.