Human Rights Brief

Volume 16 | Issue 2 Article 7

2009 Updates from the International and Internationalized Criminal Courts Shaleen Brunsdale American University Washington College of Law

Kara Karlson American University Washington College of Law

Jennifer Goldsmith American University Washington College of Law

Laura Jarvis American University Washington College of Law

Megan Chapman American University Washington College of Law

Follow this and additional works at: http://digitalcommons.wcl.american.edu/hrbrief Part of the Criminal Law Commons, Human Rights Law Commons, and the International Law Commons

Recommended Citation Brunsdale, Shaleen, Kara Karlson, Jennifer Goldsmith, Laura Jarvis, and Megan Chapman." Updates from the International and Internationalized Criminal Courts." Human Rights Brief 16, no.2 (2009): 40-44.

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updates from international and internationalized criminal courts & tribunals

Internationa l Cr i m i n a l commander Radislav Krstic´. He related them victimized only because of their Tr i b u n a l f o r t h e his experience of being captured by the ethnicity. This ICTY initiative will serve Fo r m e r Yu g o s l a v i a Bosnian Serb army, the Vojska Repub- as a useful tool for understanding and lika ­Srpska (VRS), while he was hiding appreciating the atrocities which occurred A New Face in a forest during an attempted escape in the former Yugoslavia and support the from ­Srebrenica. He had been seized efforts by the international community to In December 2008, the International and lined up in a meadow along with secure justice for the people who were Criminal Tribunal for the former Yugo- dozens of men. The men were shot and most affected. slavia (ICTY) launched a new website killed, but the boy managed to survive, giving itself a fresh, new face. The new escape, and tell his story. The Tribunal Future of the Tribunal layout, design and innovative additional convicted ­Radislav Krstic´ and sentenced content helps the ICTY achieve judicial him to 35 years’ imprisonment. Another The ICTY is working towards the com- transparency and accountability and pro- victim, Grozdana Ce´ ´cez, a 43-year-old pletion of its mandate and has devised a vides insight into challenges and achieve- Bosnian Serb woman, testified in the case plan to complete its mission successfully, ments. The new website pays tribute to against Zdravko Mucic´, Hazim Delic´, in a timely manner, and in coordination the contributions the Tribunal has made Esad Landžo, and ­Zejnil Delalic´, com- with domestic legal systems in the for- to international humanitarian law and manders and deputy commanders in the mer Yugoslavia. The Tribunal’s current human rights issues. The Tribunal hopes C ˇelebic ´ i prison camp. She had been raped goal is to complete all proceedings by to use the website to educate the interna- by Hazim Delic´ and multiple other men in 2012. Of the 161 Accused indicted by tional community about the massacre at the camp. After the experience, she said the Tribunal, only five Accused remain Srebrenica, rapes committed by members that she was driven to commit suicide in the pretrial stage, twenty-six are in the of the Bosnian Serb armed forces, and the but was stopped by another detainee who course of trial and ten have appeals pend- persecution that occurred in the Omarska, had also been raped. The case of Hazim ing. With the arrest of Stojan Župljanin Keraterm and Trnopolje camps, amongst Delic´, who was sentenced to 18 years’ and Radovan Karadžic´ on June 11, 2008 other horrendous events which will now imprisonment, was a landmark case in and July 18, 2008 respectively, only two become part of an undeniable historical international law marking the first time accused, Ratko Mladic´ and Goran Hadžic´, record. The ICTY plans to use this new the court found rape as a form of torture. are still at large. All the other cases have and improved forum to spread the ideals been completed. of international justice not only by shar- Another witness, a Bosnian army pris- ing updates on the convictions and trials oner of war testified about being tortured The ICTY has bolstered its completion of some of the most notorious criminals, in the Široki Brijeg prison near Mostar, strategy by focusing on the most senior but also by sharing the tragic stories and in southern Bosnia and Herzegovina. He leaders suspected of crimes within its the courageous voices of hundreds of was repeatedly beaten and bloodied with jurisdiction and transferring cases against victims. boots, belts and fists. He talked about intermediate and lower-level perpetra- being interrogated while being attached to tors to competent national courts set up Voice of the Victims wires from an induction telephone pass- in Bosnia and Herzegovina, Serbia, and ing electricity from his fingers to his toes. Croatia. The impact of referrals on the The ICTY created the Voice of the He recalled that for food, the prisoners overall workload of the Tribunal has been Victims section on their website to honor received a quarter loaf of bread every two significant. Ten accused have been trans- the courage and bravery of those victims or three days and no water. The Tribunal ferred to the War Crimes Section of the who testified before the Tribunal, facing convicted Mladen Naletilic´ and Vinko State Court of Bosnia and Herzegovina; the people who caused them so much Martinovic´ of a number of crimes against two were transferred to the authorities suffering. It recognizes the importance Bosnian Muslims in the Mostar area and of Croatia; and one was transferred to of giving victims a chance to tell their sentenced them to 20 and 18 years impris- Serbia for trial before the domestic courts stories to bridge the gap between the onment, respectively. of these countries. The Tribunal has con- Tribunal, situated so far away in The tinued to stay involved and monitor the Hague, and the communities who have Amongst the many stories captured progress of these trials, however, ensuring the most interest in the information about on the ICTY website run common tragic full adherence with human rights norms its work. themes of pain and suffering. Numerous and due process standards. victims’ stories of what they saw and One of the victims includes a 17-year- experienced have been featured, includ- As the ICTY enters the final years old Muslim teenager who testified in ing stories from farmers, doctors, house- of its mandate, it continues to conduct a the case against Bosnian Serb Army wives, students and children, many of wide range of outreach activities includ-

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ing the facilitation of trial coverage by Republika Srpska Army, is charged with Internationa l Cr i m i n a l local media, direct community outreach participating in the disappearances, rape, Tr i b u n a l f o r Rw a n d a in the former Yugoslavia by officers on and murder of civilians from the town of the ground, and capacity-building efforts Rogatica, BiH, in 1992. A few days later, The Prosecutor v. Protais with national judicial institutes dealing Tomo Jurinovic´ was taken into custody as Zigiranyirazo, Case No. with war crimes. The focus of the Tribu- well to be held for one month. Jurinovic´, a ICTR-01-73-T nal is now on the mechanisms that will member of the Croatian Defense Council, be left in place to address residual issues along with others, is accused of having On December 18, 2008, Trial Chamber after the completion of the cases on the taken a family from their home in Novo III of the International Criminal Tribunal Tribunal’s docket. Some of the key issues Selo, and transported them to another for (ICTR) convicted Protais being addressed include the location, pub- town. In the process, the family was Zigiranyirazo for and extermi- lic access, security, and preservation of abused, and one family member was killed. nation as a crime against humanity and ICTY records. The Tribunal has also sentenced him to 20 years imprisonment. compiled their best practices, which will Dragic´ Gojkovic´, Rada Gojkovic´ et. al. The Chamber found that the Prosecution be published and disseminated by the pled not guilty to the offense of illicit traf- failed to establish that Zigiranyirazo was United Nations Interregional Crime and ficking in arms, military equipment, and criminally responsible for conspiracy to Justice Research Institute (UNICRI), their products of dual use. They are charged commit genocide, complicity in genocide partner in this endeavor. with abusing their authority and duty by and murder as a crime against humanity. facilitating the illegal sailing and import- As the Tribunal’s work winds down, ing of military ships into BiH through Protais Zigiranyirazo, also known as it remains committed to ensuring that the country’s harbors and ports. Momir “Mr. Z,” was born in 1938 in the prefec- its achievements endure. The capture of Pelemiš and Slavko Peric´, suspected of ture of Gisenyi, Rwanda. He served as the the two remaining fugitives, Mladic´ and committing genocide, pled not guilty. Prefect of Ruhengeri between 1974 and Hadžic´, are of utmost importance to the They are charged with permanently and 1989. Although he subsequently became ICTY and the United Nations Security forcibly transferring Bosniak civilians a businessman, he remained influential in Council. Serge Brammertz, chief prosecu- from a UN safe area in Srebenica in order politics by virtue of the fact that his sister, tor of the ICTY, confirmed that efforts to execute Bosniak men and boys. Agathe Kanzig, was married to President are being taken in the collaboration with Juvénal Habyarimana. According to the Serbian authorities for the two renegade The busy docket shows that the WCC Prosecution, Zigiranyirazo was a member defendants to be brought in while the is making progress fulfilling its objectives. of Habyarimana’s entourage and thus ICTY is still functioning. Many difficulties still exist, however. The exercised a great deal of de facto authority need for increased legal resources and over the military, the , and The ICTY will be remembered as the better and more widespread protection of government officials. In 2005, the Pros- first and most successful international witnesses from intimidation and violence ecution charged Zigiranyirazo with five criminal institution, and its legacy will are still prevalent. These deficiencies counts under the ICTR Statute, namely continue through its partnerships with in meeting the needs of victims further conspiracy to commit genocide, genocide, domestic judicial institutions in the for- endorse the need for a sustained interna- complicity in genocide, extermination as mer Yugoslavia. The Tribunal has urged tional presence. The achievements of the a crime against humanity, and murder as the Security Council to continue support WCC and its international and national a crime against humanity. Zigiranyirazo’s of these institutions to ensure the devel- judiciary benefactors, however, will hope- trial took place between October 3, 2006 opment of a peaceful society based on the fully provide guidance and direction as and May 29, 2008. rule of law. well as a basis for the country’s judicial and political system for the future. The At trial, the Prosecution put forth five incidences of the accused’s involvement Wa r Cr i m e s Ch a m b e r s i n eventual transition from combined inter- in genocide: the massacres at Kesho Hill t h e Co u r t o f Bo s n i a a n d national and domestic judges to strictly He r z e g o v i n a local and regional judges will set the and Rurunga Hill; and roadblocks in foundation for future peace and stability Gisenyi ­préfecture, Kiyovu, and The War Crimes Chamber (WCC): and will begin to provide confidence in préfecture. Genocide is defined as per- Court of Bosnia and Herzegovina (BiH), Bosnia and Herzegovina’s autonomy and forming one of five enumerated acts with assisting the case load of the ICTY, sovereignty. the specific intent to destroy in whole handles litigation of low and mid-level or in part, a national, ethnic, racial, or ranked suspects regarding a wide range of religious group as such. A person can be major and minor crimes. charged with genocide even if that person did not directly carry out any physical act On January 15, 2009 Stojan Perkovic´ of violence. In this case, the Prosecution was taken into custody. He will be held for claimed that Zigiranyirazo was liable for one month due in part to a belief that he genocide by either (i) ordering, instigat- may attempt to influence witnesses. Perk- ing, or committing joint criminal enter- ovic´, a former squad commander in the prise (JCE) or (ii) aiding and abetting.

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While the Chamber held that the those meetings in its indictment against and massacres referred to in the indict- Prosecution failed to establish that the the accused. In addition, while the Cham- ment took place, but did deny that he was accused’s involvement amounted to geno- ber did agree with the Prosecution that in any way involved in the events. Based cide in respect to the roadblocks in ­Fisenyi the accused held a position of influence on the evidence presented at trial, how- préfecture and Kiyovu cellule, Kiglaie within the Habyarimana administration, it ever, the Chamber found Nchamihigo’s préfecture, it did find that ­Zigiranyirazo was not convinced by the allegations that alibi to be unbelievable and determined bore criminal responsibility for acts of Zigiranyirazo was involved in the estab- that the Prosecution had established the genocide at the Kiyovu roadblock and lishment or support of the Interahamwe. accused’s guilt on each of the charges at Kesho Hill. Specifically, the Cham- Finally, the Chamber found that the Pros- beyond a reasonable doubt. ber found that the accused was guilty of ecution failed to lead evidence in support genocide through aiding and abetting acts of other allegations underlying the charge One interesting aspect of the judgment of genocide at the Kiyovu roadblock by of conspiracy, including the claims that is the Trial Chamber’s consideration as (i) offering firearms to those manning the Accused had entered into an agree- to whether the Prosecution’s charge of the roadblock, (ii) giving instructions ment on 11 February 1994 with his sister genocide could be supported by evidence to check identity papers, and (iii) order- and Colonel Anatole Nsengiyumva to that Nchamihigo was responsible for the ing Cor­poral Irandemba to ensure food kill the enemy and accomplices and that killing of moderate Hutus. The Chamber was brought to the roadblock so that the the three had established a list of Tutsi began its analysis of this question by not- men could remain at the roadblock. In and Hutu to be killed. Thus, the Chamber ing that genocide is “a crime against a addition, the Chamber determined that concluded that the Prosecution failed to national, ethnic, racial or religious group Zigiranyirazo had participated in a JCE, establish Zigiranyirazo’s criminal respon- committed with intent to destroy the group the purpose of which was to kill Tutsis sibility for conspiracy to commit geno- in whole or in part.” It then concluded at Kesho Hill, and that the Accused pos- cide. As to the remainder of the charges, that, although Hutu political opponents of sessed the requisite genocidal intent. The the Chamber found insufficient evidence the 1994 regime were a “group,” killing Chamber also found that Zigiranyira- to establish the accused’s responsibility the members of that group did not amount zo’s acts at Kesho Hill, which included for complicity in genocide or the crime to genocide because the group was not a accompanying a group of government against humanity of murder. national, ethnic, racial or religious group. officials, Interahamwe, and civilians to The Chamber nevertheless found that the hill where a number of Tutsi refugees The Prosecutor v. Siméon Nchamihigo was responsible for the kill- had gathered and giving a speech to the Nchamihigo, Case No. ing of Tutsis with intent to destroy that group before massive ­killings of the Tut- ICTR-01-63-T group in whole or in part and thus con- sis began, constituted the crime against victed him of genocide. Furthermore, the humanity of extermination. On September 24, 2008, Trial Cham- Chamber used the evidence of Nchami- ber III of the ICTR convicted Siméon higo’s involvement in the killing of Hutu Despite finding that the accused par- Nchamihigo for genocide and the crimes moderates to support the Prosecution’s ticipated in a joint criminal enterprise to against humanity of murder, extermina- charge of the crime against humanity of commit genocide at Kesho Hill and that tion, and other inhumane acts. The Cham- extermination. he aided and abetted acts of genocide at ber sentenced him to imprisonment for Kiyovu roadblock, the Chamber found life. Nchamihigo was a Rwandan deputy The Nchamihigo judgment also insufficient evidence that Zigiran­yirazo prosecutor in Cyangugu province prior includes a notable discussion on the issue had entered into a conspiracy to com- to, and during, the in of sentencing. The Prosecution asked for a mit genocide. The Prosecution argued 1994. Then in July 1998, he began work- life sentence in order to punish the crime, that, before and after the death of Pres- ing as an investigator for the ICTR under deter future crimes, and properly reflect ident Habyarimana on April 6, 1994, the false name of Sammy Bahati Weza. the suffering of the victims. In response, ­Zigiranyirazo met with government, mili- He did this until May 2001, when he was the Defense argued that the Tribunal’s tary and family authorities in the préfec- identified by a witness at a trial taking punishment should not be an act of ven- tures of Kigali-ville and Gisenyi to plan, place at the ICTR and was arrested. geance, but rather should be balanced with prepare, and facilitate attacks on Tutsis. compassion. It also asked the Chamber to According to the allegations, the intent of The Prosecution charged that Nchami- consider Nchamihigo’s good character the planners was to destroy, in whole or in higo was responsible for the alleged crimes and the fact that he was a good father. In part, the Tutsi ethnic group. In addition, based on his planning, instigating, order- making its determination, the Trial Cham- the Prosecution alleged that Zigiranyirazo ing, committing, and aiding and abetting ber considered the gravity of the crimes was involved with creating and support- of others in the killing of Tutsis, accom- committed and aggravating and mitigat- ing the Interahamwe. plices of the Rwandan Patriotic Front, ing factors. The Chamber focused on the and Hutu political opponents. According fact that Nchamihigo had directly and The Chamber refused to consider a to the Prosecution, these acts resulted in personally committed many of the crimes number of the meetings relied upon by the the killing of specific individuals, kill- for which he was convicted, as opposed Prosecution to establish the conspiracy ings at roadblocks, and the massacre of to aiding and abetting those crimes. In charge, though, on the ground that the Tutsis seeking refuge in various locations. addition, the Chamber stressed that, as a Prosecution had not included reference to Nchamihigo did not deny that the killings deputy prosecutor during the time of the

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genocide, Nchamihigo was expected to not “voluntarily” participate in armed in an “appropriate state,” the prosecu- “uphold the rule of law and principles of conflict. tion attempted to call the boy’s father as morality.” Instead, he planned and pro- a second witness. The testimony of this moted violence. Moreover, others trusted Following the Prosecution’s opening, witness, however, was delayed due to a him because of his position and believed the representatives of approximately 100 finding by the Court that the witness had that they could commit the acts they did victims participating in the Lubanga trial, not been adequately informed regarding without consequences. Thus, the Cham- who have been divided among seven the risk of self-incrimination. ber concluded that Nchamihigo created groups, each with its own counsel, gave an environment in which atrocities could brief opening statements. Several of the Two weeks later, both witnesses take place and expressed no remorse. victims’ attorneys focused on the rape returned and testified before the Court. While the Chamber did not deny that he of girl child soldiers in their opening The former child soldier was permitted was a good father, it held that this fact did statements. to tell his story without interruption from not have a large impact on the sentencing the Prosecution, victims’ representatives, The Defense presented opening state- and found that mitigation was not war- or the Defense. Although Lubanga could ments on the second day of trial, arguing ranted based on any other circumstances. view the witness on a video monitor, that Lubanga’s fair trial rights had been the witness and Lubanga could not see ICC compromised by delay, insufficient dis- each other directly. Upon returning to closure, and a plethora of ex parte meet- the stand, the former child soldier testi- Lubanga Trial Started ings held between the Chamber and the fied that soldiers from Lubanga’s militia Prosecution, outside of the presence of the kidnapped him and took him to a training The trial for Thomas Lubanga Dyilo, accused or his counsel. The Defense also camp. The witness testified that he and the first suspect to be tried before the claimed that Lubanga is simply a “scape- other children were beaten for being tired, International Criminal Court (ICC) started goat” who is being tried by the ICC at the sick, or trying to escape. on January 26, 2009. Lubanga is charged behest of DRC President Joseph Kabila’s with the war crimes of conscripting, government. Finally, Lubanga’s counsel Pre-Trial Chamber Considers enlisting, and using children under the objected to the fact that both the Prosecu- Bemba Charges age of fifteen in armed combat. Lubanga tion and the victims’ legal representatives has pled not guilty to the charges against discussed allegations of sexual abuse in The ICC held the confirmation of him. their opening statements, even though charges hearing in the case against Jean- no charges of sexual violence have been Pierre Bemba Gombo between January Lubanga was a leader in the Union of formally entered by the Prosecution or 12 and January 15, 2009. To date, Bemba Congolese Patriots (UPC), a rebel group confirmed by the Court. is the only person charged in connection operating in the Democratic Republic of with the situation in the Central African Congo (DRC) with close ties to Uganda. Witness Confusion at Republic (CAR), although the investiga- He was arrested by the DRC in March Lubanga Trial tion is ongoing. Bemba is accused of rape, 2005 and transferred to the ICC one year torture, and murder as crimes against later pursuant to an arrest warrant issued The Prosecution’s first witness in the humanity and rape, torture, outrages upon by the Court’s Pre-Trial Chamber I. Lubanga case was to testify about his personal dignity, pillage, and murder as experiences as a child soldier in Lubanga’s war crimes. The Prosecution’s opening statement army. The witness originally told ICC recounted witness statements provided investigators that Lubanga’s men had The Pre-Trial Chamber presiding over to ICC investigators about beatings kidnapped him while walking home from the Bemba confirmation proceedings must Lubanga’s soldiers used to enforce dis- school and that they took him to a training now decide to: (i) confirm the charges cipline among children being used as camp for child soldiers. His testimony, proposed by the Prosecution; (ii) dismiss soldiers and to discourage attempts to however, quickly changed, stating that he the charges; or (iii) adjourn the hearing escape. It also presented video footage of could not answer the Prosecutor’s ques- and request that the Prosecution present Lubanga with bodyguards who were, in tions because he had taken an oath. The further evidence on a particular charge the words of the Prosecutor, “manifestly witness took the stand after a short recess or amend the charges. The Chamber is under the age of fifteen.” Moreover, the and stated that his statement was not true. required to issue its decision within sixty Prosecution told stories of female child He told the court an unidentified human days of the submission of final observa- soldiers that included “daily examples of rights organization told him what to say. tions from the parties on matters that commanders raping girl soldiers.” Chief arose at the confirmation hearing. Prosecutor Luis Moreno Ocampo said that Fearing he would not be safe when it is his “mission” to show that Lubanga he went back to the DRC, the Prosecu- was criminally responsible for the “atroci- tion claimed that the witness changed his ties committed against those little girl sol- statement and therefore requested pro- diers.” Lastly, the Prosecution reminded tective measure for the witness and his the Trial Chamber that, under the Rome family. After the court decided that the Statute governing the ICC, children can- first witness could not testify until he was

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Th e Extraordinary staff were paying bribes to retain their its allocation of nearly $3.5 million to Ch a m b e r s i n t h e positions. Reportedly a common practice support the ECCC. Despite widespread Co u r t s o f Ca m b o d i a in other areas of government work in fears of corruption within the ECCC, Cambodia, such corruption caused many the international community and donors Corruption Stalls Progress international funding sources to withhold remain committed to the fair and timely in the ECCC funds while the UN responded to the completion of the trials, keeping in mind charges. As a result, the approximately that the old age and health conditions of Progress in prosecuting former mem- 250 Cambodian staff had their paychecks many of the accused require that justice bers of the Khmer Rouge has been slow as withheld. Given the hybrid nature of the be rendered before it is too late. HRB the Extraordinary Chambers in the Courts tribunal with a system that integrates of Cambodia (ECCC) have experienced Cambodian and international workers, an increase in criticism during the last the functioning of the ECCC is threat- Shaleen Brunsdale, a J.D. candidate at year. In particular, the ECCC has been ened by the possibility that Cambodian the Washington College of Law, covers charged by funding sources, the media, workers will leave their employment if the ICTY and the Bosnian War Crimes and the international community with they remain unpaid. Although the UN is Chambers for the Human Rights Brief. pervasive corruption that has resulted in attempting to investigate the complaints, Kara Karlson is a J.D. candidate at the profound delays in the delivery of justice. the Cambodian government asserts that it Washington College of Law and covered The ECCC has made some notable prog- holds jurisdiction over these allegations. the ICC for this issue of the Human Rights ress in the way of preliminary decisions Brief. since its inception in 2006, including its The tension over defining the proper authority to review the recurring com- first public hearing, on the pretrial deten- Jennifer Goldsmith is a J.D. at the Wash- plaints of corruption and kickbacks is tion of Kaing Guek Eav (also known as ington College of Law and wrote Pros- symptomatic of the setbacks of the ECCC. Duch), who commanded the infamous ecutor v. Protais Zigiranyirazo for the In its October 2008 update on develop- Khmer Rouge torture center, Toul Sleng. Human Rights Brief. In spite of this progress and the arrests of ments in the ECCC, the Open Society high profile officials like Khieu Samphan, Institute’s Justice Initiative noted prob- Laura Jarvis is a J.D. candidate at Wash- who served as head of state during the lems of inadequate transparency and ington College of Law and wrote Prosecu- Khmer Rouge era, the Chambers have administrative divisions stemming from tor v. Siméon Nchamihigo for the Human been plagued with various set backs and corruption allegations and recommended Rights Brief. have yet to hold their first trial. that donors condition funding on “the meaningful resolution of longstanding Megan Chapman is a J.D. candidate at With a timeline to wrap up operations concerns about perceived corruption at Washington College of Law and covered in Cambodia by 2010, the ECCC must the ECCC.” Given conflicts over jurisdic- the ECCC for this issue of the Human act to expeditiously try those charged. tion, no progress has been made towards Rights Brief. In July 2008, the UN received a number resolving corruption allegations. None- of complaints that ECCC’s Cambodian theless, Australia has recently announced

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