View metadata, citation and similar papers at core.ac.uk brought to you by CORE provided by Valparaiso University Valparaiso University Law Review Volume 51 Number 3 Spring 2017 pp.831-879 Spring 2017 To The People: Enhancing Leahy Law Human Rights Enforcement Through a Private Cause of Action Jess Hunter-Bowman Valparaiso University Follow this and additional works at: https://scholar.valpo.edu/vulr Part of the Law Commons Recommended Citation Jess Hunter-Bowman, To The People: Enhancing Leahy Law Human Rights Enforcement Through a Private Cause of Action, 51 Val. U. L. Rev. 831 (2017). Available at: https://scholar.valpo.edu/vulr/vol51/iss3/9 This Notes is brought to you for free and open access by the Valparaiso University Law School at ValpoScholar. It has been accepted for inclusion in Valparaiso University Law Review by an authorized administrator of ValpoScholar. For more information, please contact a ValpoScholar staff member at
[email protected]. Hunter-Bowman: To The People: Enhancing Leahy Law Human Rights Enforcement Throu TO THE PEOPLE: ENHANCING LEAHY LAW HUMAN RIGHTS ENFORCEMENT THROUGH A PRIVATE CAUSE OF ACTION I. INTRODUCTION A sudden burst of machine-gun fire tore through the walls of Alfonso Bolivar Tuberquia’s home in rural Colombia.1 Seconds later, a grenade exploded, killing his wife, Sandra.2 Alfonso’s two young children miraculously survived the hail of bullets and shrapnel, prompting paramilitary commanders and their Colombian military allies to callously discuss what to do with the children.3 “Assassinate the kids, but silently,” a paramilitary commander ordered.4 A paramilitary fighter complied; he “took the child by the hair and slit her throat with a machete.”5 In total, eight civilians, including three children, were brutally massacred before paramilitaries and troops from the Colombian military’s Seventeenth Brigade marched out of San José de Apartadó.6 Days after the massacre, community members and human rights organizations alerted the U.S.