Jean-Marc Rouillan was a founder and leader of Action Directe, a far-left armed group active in France in the 1980s. He was sentenced to life imprisonment by the cour d'assises spéciale de Paris in 1989 and again in 1994, each time with an 18-year minimum period, in the cases of the killings of 1985 and 1986. The dead were René Audran, who was killed in 1985, and Georges Besse, who was killed in November 1986. Rouillan was arrested in February 1987 together with three other leading members of the group.
After about 25 years in custody he was released on conditional release on May 15, 2012. His later legal history concerns what he said rather than what he did in the 1980s. In 2016 he was convicted of complicity in public apology for terrorism over a radio interview, and the European Court of Human Rights ruled in 2022 that the length of the prison sentence for it violated his right to freedom of expression. A new sentence of eight months was imposed at Toulouse in December 2023 and was upheld by the highest criminal court in France on December 2, 2025.
Action Directe was founded in 1979, and Rouillan was among its founders. He was arrested in September 1980 and freed under an amnesty a few months later. He and a minority of the group chose to continue, and in 1985 the group joined forces with a West German armed group. The killings for which he was later sentenced date from 1985 and 1986.
In February 1987 Rouillan and three other leading members of Action Directe were arrested. For most of some fourteen years after the arrests the four were held under varying degrees of isolation.
The four leading members were tried in two proceedings before the cour d'assises spéciale de Paris. The verdicts were delivered on January 14, 1989 and May 19, 1994, and in each case the sentence was life imprisonment with an 18-year minimum period. The European Court of Human Rights, in its 2022 judgment, set out his sentences as life imprisonment (réclusion criminelle à perpétuité) in 1989 and in 1994, each carrying an 18-year minimum period (peine de sûreté).
The offenses listed in the judgment are "assassinat à caractère terroriste" (terrorist murder), complicity in that murder, criminal association, handling stolen goods, offenses under the arms law, destruction of property, and complicity in murder.
The 1994 sentences were multiple terms of life imprisonment for politically motivated acts of violence, including murder.
The minimum periods attached to the life sentences ended in 2007. Rouillan then received a form of semi-liberty, which allowed him to work outside, and from 2007 he worked for a publisher. At the end of 2008 the semi-liberty was revoked after he gave a press interview about the group's past acts, and he returned to full custody. In April 2011 the Paris Court of Appeal granted him semi-liberty again, to begin on May 19, 2011, with an electronic tag. The conditions included working, compensating his victims and not discussing the facts.
Rouillan has been on conditional release since May 15, 2012. The terms are that he may not distribute any work he wrote or co-wrote that deals in whole or in part with the offense, and that he must refrain from any public intervention relating to the offense. The European Court records that he served 25 years in custody before the release.
On February 23, 2016, Rouillan gave a 58-minute interview to two journalists. It was broadcast the same day on a programme made by a Marseille magazine with a local radio station and was posted online that evening. Speaking of the perpetrators of the November 2015 attacks in Paris and Seine-Saint-Denis, he made remarks that the courts later treated as an apology for terrorism. A lawyer for victims of those attacks reported the remarks to the Paris prosecutor on March 7, 2016, and a preliminary investigation opened the same day. An association of victims of terrorism and several victims of the attacks joined the case as civil parties.
On September 7, 2016 the Paris criminal court convicted him of public apology for an act of terrorism by an online communication service and sentenced him to eight months' imprisonment, with 1 euro in damages to the victims' association and 300 euros to each victim who was a civil party. On May 16, 2017 the Paris Court of Appeal reclassified the offense as "complicité d'apologie publique d'actes de terrorisme au moyen d'un service de communication accessible au public en ligne" and raised the sentence to 18 months, of which 10 were suspended with probation. The Constitutional Council ruled on May 18, 2018 that the provision under which he was prosecuted was consistent with the Constitution, and the Court of Cassation dismissed his appeal on November 27, 2018. He served the custodial part under electronic monitoring from July 9, 2020 to January 12, 2021.
Rouillan applied to the European Court of Human Rights on May 20, 2019. In its judgment of June 23, 2022 (application no. 28000/19) the Court accepted that the interference with his freedom of expression was prescribed by law and pursued the aims of preventing disorder and crime. It held that his remarks, in their context and given the positive image of the perpetrators that they conveyed, amounted to indirect incitement to terrorist violence. It nonetheless found a violation of the guarantee of freedom of expression because the reasons given for an 18-month custodial sentence were not sufficient to show that it was proportionate. The finding of a violation was held to be sufficient compensation for non-pecuniary damage, and France was ordered to pay 15,000 euros for costs and expenses.
On March 9, 2023 the Cour de révision et de réexamen annulled the sentencing provisions of the 2017 judgment and sent the question of sentence to the Toulouse Court of Appeal. On December 19, 2023 that court sentenced him to eight months' imprisonment without suspension. Rouillan argued that the court had not drawn the consequences of the European judgment. On December 2, 2025 the criminal chamber of the Court of Cassation dismissed the appeal. It held that the Toulouse court had identified exceptional circumstances justifying a custodial sentence given the context and his background, and that a sentence lower than the 2017 sentence and no higher than the 2016 first-instance sentence was not disproportionate.
The cour d'assises spéciale de Paris tries terrorism cases. A life sentence with a minimum period (peine de sûreté) means that the person cannot ask for the sentence to be adjusted until the minimum has been served; in Rouillan's case the minimum periods ran out in 2007.
Which offense was found in which of the two trials, and so how each death was treated, has not been set out: the European Court's list of offenses covers both trials together.
1979: Action Directe is founded.
September 1980: Rouillan arrested, then freed under an amnesty a few months later.
1985: Audran killed.
November 1986: Besse killed.
February 1987: Rouillan and three other leading members arrested.
January 14, 1989: first life sentence passed on a co-defendant by the cour d'assises spéciale de Paris; Rouillan sentenced to life in 1989.
May 19, 1994: second life sentences; Rouillan sentenced to life in 1994.
2007: minimum periods end; semi-liberty begins.
End of 2008: semi-liberty revoked after a press interview.
April 2011: Paris Court of Appeal grants semi-liberty from May 19, 2011.
May 15, 2012: conditional release begins.
February 23, 2016: radio interview.
September 7, 2016: convicted, eight months.
May 16, 2017: Court of Appeal, complicity in public apology for terrorism, 18 months (10 suspended).
November 27, 2018: Court of Cassation dismisses appeal.
July 9, 2020 to January 12, 2021: sentence served under electronic monitoring.
June 23, 2022: European Court of Human Rights finds a violation over the severity of the sentence.
March 9, 2023: sentence annulled and sent to Toulouse.
December 19, 2023: Toulouse Court of Appeal, eight months' imprisonment.
December 2, 2025: Court of Cassation dismisses his appeal.