When one state wages an aggressive war against

the UN Charter, to use force in self-defense. When one state wages an aggressive
war against another, it is easy to see how a large-scale use of force could be war-
ranted as a response and how the jus ad bellum criteria could govern this decision.
However, the evolving notion of threat illustrates the need for a more calibrated
view of force. In cases of threat associated with terrorism, humanitarian cata-
strophe, and the spread and use of weapons of mass destruction, the potential
for signi fi cant human rights violations warrants some kind of response, but not
necessarily the declaration of a full-scale international war.
According to recent research by the Council on Foreign Relations, between
 and June of  the United States carried out thirty-six “ discrete military
operations, ” which they de fi ne as “ a single or serial physical use of kinetic military
force to achieve a de fi ned military and political goal by in fl icting casualties or
causing destruction, without seeking to conquer an opposing army or to capture
or control territory. ”

Considering additional uses of force complicates matters
more. No- fl y zones — which utilize air power in support of peace operations by
denying the enemy use of designated air space, and provide a means for monitor-
ing ground operations

— arguably constitute a lower level of force compared to
war, though they still require some level of violence to enforce. No- fl y zones
have been employed three times in the last two decades, namely, in Iraq from
 to  , Bosnia and Herzegovina from  to  , and Libya in  .
While seemingly less violent than full-scale war, they have signi fi cant costs insofar
as they require strong regional support to access local air bases and acquire
fl y-over permission. Moreover, their maintenance requires the implied threat of
force, which puts multiple categories of peoples — civilians and soldiers — at risk.
As Coady argues, the Iraq containment zone opened the way for human rights
from jus ad bellum to jus ad vim
93
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violations by authorizing approximately  ,  sorties per year between  and
 . Coady points to  civilian deaths as well as “ many Iraqi military deaths
and much property destruction ” that lack adequate documentation.

In addition, despite the  report by the International Law Association on the
meaning of armed con fl ict that argues that terrorist attacks do not amount to just
cause for small-scale uses of force,

U. S. government of fi cials continue to operate
within a moral gray zone created by the increased in fl uence of nonstate actors,
which, some argue, blurs the relationship between morality, international law,
and the use of force.