At Nsabimana's installation ceremony, the President of the interim government Théodore Sindikubwabo reportedly gave a speech calling for the murder of Tutsis.
[1] Mugenzi's case was among several successful appeals in the ICTR and International Criminal Tribunal for the former Yugoslavia after the "specific direction" standard was introduced under Meron's leadership.
[3] The Trial Chamber had determined that Mugenzi had acted with genocidal intent when he decided to "undercut the real and symbolic resistance [Habyalimana] posed to the killing of Tutsi civilians inhabiting or seeking refuge in Butare".
Under the Trial Chamber's mens rea analysis Mugenzi shared a "common criminal purpose" and thus possessed the same genocidal intent as interim President Sindikubwabo.
The Appeals Chamber found that a reasonable trier of fact could not rule out the possibility that Mugenzi could have attended the ceremony out of social obligation and reversed the conviction for "direct and public incitement to commit genocide".