How does the Supreme Court’s Hayes/Gianturco doctrine apply to unlawful military orders?

1. What you asked for and what the record here actually contains

You asked how the Supreme Court’s Hayes/Gianturco doctrine applies to unlawful military orders, but none of the supplied documents or news links reference a Supreme Court decision called Hayes or Gianturco or a doctrinal rule by that name; therefore I cannot attribute any principles to that label using these sources (available sources do not mention Hayes/Gianturco). The available items instead include joint doctrine and service legal guidance about commanders and operations ^{[1] [2] [3]}, and news reporting and commentary about recent domestic military deployments and debate over unlawful orders ^{[5] [6] [7]}.

2. What U.S. military doctrine says about lawful command and orders

Joint doctrine and service publications set out that commanders exercise authority and that doctrine governs activities and joint operations; these publications are the baseline for how orders are issued and implemented, including legal considerations for operations and interagency coordination ^{[1] [2]}. The 2025 joint publications emphasize that military guidance covers the exercise of authority by combatant commanders and other joint force commanders and prescribes doctrine for operations and training ^[1].

3. Military legal guidance on unlawful orders and the commander’s responsibilities

Military legal guidance and handbooks — such as The Military Commander and the Law — are part of the available corpus and address legal limits on orders, commanders’ responsibilities, and consequences like nonjudicial punishment or courts-martial; these references form the service-level legal framework that soldiers and commanders rely on when confronted with potentially unlawful directives ^[3]. The exact tests and criminal/civil remedies that apply to refusing orders are matters typically handled in those manuals and in military justice practice rather than in the doctrinal joint publications summarized here ^[3].

4. Public debate, domestic deployments, and the “unlawful orders” controversy

Recent reporting in the supplied results shows contemporary political and legal controversy over deploying federal forces and National Guard units for domestic law enforcement tasks; Reuters and the Wikipedia summary document expanded domestic deployments in 2025 and court challenges under statutes such as Posse Comitatus were reported ^{[6] [7]}. Commentary pieces—examples include a Military.com column—warn that lectures about “unlawful orders” can cause confusion among service members and the public, indicating competing views on how best to communicate the limits on orders and the risks of politicizing military obedience ^[5].

5. Two competing practical perspectives in the record

One practical view present in these materials is institutional: doctrine and manuals provide the formal framework for lawful orders and internal redress; they emphasize chain-of-command processes, legal review, and military justice mechanisms ^{[1] [3]}. A competing public-policy view evident in news reporting and commentary stresses accountability and civilian oversight when troops are used domestically and warns about potential illegal uses of force or politicized orders; litigation (e.g., Posse Comitatus challenges reported) is the public check referenced in the files ^{[6] [7] [5]}.

6. What I cannot say from these sources and recommended next steps

I cannot confirm the content, existence, or scope of any “Hayes/Gianturco doctrine” from the supplied documents because that term does not appear in these materials (available sources do not mention Hayes/Gianturco). If you want an authoritative answer tied to case law, provide the text or citation of Hayes and Gianturco, or allow me to search broader legal databases and Supreme Court records; alternatively, I can analyze how established military-law principles and recent litigation over domestic deployments (Posse Comitatus-related reporting) would generally interact with any Supreme Court doctrine if you can supply that doctrine’s language.