Michigan Law Review Volume 109 Issue 6 2011 Liberal Legal Norms Meet Collective Criminality John D. Ciorciari Gerald R. Ford School of Public Policy, University of Michigan Follow this and additional works at: https://repository.law.umich.edu/mlr Part of the Criminal Law Commons, Human Rights Law Commons, and the Organizations Law Commons Recommended Citation John D. Ciorciari, Liberal Legal Norms Meet Collective Criminality, 109 MICH. L. REV. 1109 (2011). Available at: https://repository.law.umich.edu/mlr/vol109/iss6/15 This Review is brought to you for free and open access by the Michigan Law Review at University of Michigan Law School Scholarship Repository. It has been accepted for inclusion in Michigan Law Review by an authorized editor of University of Michigan Law School Scholarship Repository. For more information, please contact
[email protected]. LIBERAL LEGAL NORMS MEET COLLECTIVE CRIMINALITY John D. Ciorciari* MAKING SENSE OF MASS ATROCITY. By Mark Osiel. Cambridge: Cambridge University Press. 2009. Pp. xviii, 257. £50. INTRODUCTION In early 2008, a Cambodian survivor confronted a Khmer Rouge lead- er for the first time at a U.N.-backed tribunal in Phnom Penh. Facing Pol Pot's infamous deputy, Nuon Chea, she recounted her parents' untimely deaths and her brutal imprisonment at age seven, when she was shackled beside her four-year-old brother. Nuon Chea has denied responsibility for these and other atrocities during the Khmer Rouge reign of terror in the late 1970s, but the victim asked plaintively, "If Nuon Chea claimed he was not responsible, who was then for the loss of my parents and other vic- tims' loved ones?"' That plea drove to the heart of the challenge of accounting for mass atrocity.