of at least 12 military members. If the defendant is an enlisted service member, he or she may opt for at least one-third of the panel to also be of enlisted rank. All members of the panel must outrank the accused. The defendant cannot plead guilty to the charges. A two-thirds majority is enough for conviction, but unanimity is required to issue a death sentence during the penalty phase of the proceeding. All death sentences are automatically appealed, first to the Court of Criminal Appeals for the military service concerned, then to the United States Court of Appeals for the Armed Forces. The sentence must be personally confirmed by the President of the United States. Military executions would be conducted under regulations issued on 17 January 2006, and would ordinarily take place at the Special Housing Unit of the United States Disciplinary Barracks (USDB), Fort Leavenworth, Kansas, although alternative locations are possible (such as the Federal Correctional Complex, Terre Haute, Indiana, where federal civilian death-row inmates are housed and executed). Of four convicted servicemen awaiting execution, three are confined at the USDB's Special Housing Unit and one at Camp Lejeune, all of whom have been convicted of murder. Prior to 1991, the methods of execution approved by Headquarters, Department of the Army were hanging, firing squad (musketry) or electrocution. Electrocution was added as an option in the 1950s but could only be used at a specific confinement facility designated by Headquarters, and only be performed by a professional civilian executioner. An electric chair was installed at the old United States Disciplinary Barracks at Ft. Leavenworth, KS, but was never used. The last military execution occurred in 1961 by hanging. Currently, lethal injection is the only method. Separately, military commissions may be also established in the field in time of war to expeditiously try and sentence enemy military personnel under the UCMJ for certain offenses. Controversially, the Military Commissions Act of 2009 allows military commissions to try and sentence alien unprivileged enemy belligerent[s] accused of having engaged in or purposefully and materially support[ed] hostilities against the United States or its allies, without the benefit of some UCMJ protections. In a military commission trial, the death penalty may only be imposed in case of a unanimous verdict and sentencing decision. Previous use The Creek War In 1814, Private John Wood was executed by a firing squad for assaulting a superior officer. American