Politics Trivia! - Rape-Minded Woman Prosecuted for War Crimes in Rwanda.

[QUOTE=xec8;1001049]We need to smartalize this place up a little bit. Whenever I find an interesting and well-written political article, I'll post it.

Check this out. During the massacre in Rwanda back in '94, one of the Hutu leaders, a woman, actively encouraged her Hutu followers to rape as many Tutsi women as possible. So if you're a Tutsi woman and lucky enough to survive, chances are that you're probably going to get raped. And your aggressors are only following orders given them by a woman.

The article is superlong so I'm only posting a very small part of it:[/QUOTE]First!!

I'll read all that when I have 45 minutes to spare.

I've been watching documentaries on the region, also started reading "What is the What" from Eggers. Unbelievable stuff.

Where are your footnotes?

[QUOTE=monkeywright;1001055]I've been watching documentaries on the region, also started reading "What is the What" from Eggers. Unbelievable stuff.

Where are your footnotes?[/QUOTE]
Relevant footnotes:

(1) See Prosecutor v. Nyiramasuhuko, Case No. ICTR-97-21-I, Amended Indictment (Aug. 10, 1999), at [url]www.ictr.org/ENGLISH/cases/Nyira/indictment/index.pdf[/url] (last visited Apr. 10, 2004) (naming offenses stipulated in Articles 2, 3, and 4 of the ICTR Statute).

(2) See Peter Landesman, The Minister of Rape: How Could a Woman Incite Rwanda's Sex-Crime Genocide?. N.Y. Times Mag., Sept. 15, 2002, at 82. The New York Times Magazine depicted Nyiramasuhuko on its cover in a striking graphic. Male officials who incited similar violence against women in Rwanda or other conflicts have not received similar publicity by the news media; however, the implications of this discrepancy are beyond the scope of this Article.

(3) See Human Rights Watch & Federation Internationale Des Ligues Des Droits De L'Homme, Shattered Lives: Sexual Violence During the Rwandan Genocide and its Aftermath 1 (1996), available at [url]www.hrw.org/reports/1996/Rwanda.htm[/url] (last visited Apr. 10, 2004) [hereinafter Human Rights Watch, Shattered Lives]; see also Alison Des Forges, Human Rights Watch, Leave None to Tell the Story, Genocide in Rwanda (1999), available at [url]www.hrw.org/reports/1999/rwanda/[/url] (last visited Apr. 10, 2004) (describing the events leading up to the genocide and the violence that occurred in specific areas in extensive detail); see generally African Rights, Rwanda: Death, Despair and Defiance (1995) (providing a comprehensive overview of the genocide from personal, communal, and national perspectives).

(4) Compare Republic of Rwanda, Genocide and Justice, at [url]www.rwandal.com[/url] (last visited Feb. 16, 2003) (reporting that one million Rwandan citizens were killed in one hundred days), with International Criminal Tribunal for Rwanda Handbook for Journalists, available at [url]www.ictr.org/ENGLISH/handbook/index.htm#1[/url] (last visited Mar. 3, 2004) (estimating that approximately 800,000 individuals were killed during the three month period). See also Press Release, United Nations, Detailed Report on Situation of Rape, Widowed, Landless and Otherwise Traumatized Women in Rwanda presented to the Anti-Discrimination Committee, U.N. Doc. WOM/896 (Feb. 1, 1996), at [url]www.un.org/News/Press/docs/1996/19960201.wom896.html[/url] (last visited Mar. 25, 2004) (reporting that the 1994 genocide left 500,000 women widowed and 400,000 children orphaned); Human Rights Watch, Shattered Lives, supra note 3, at 35 (emphasizing that Rwanda has "become a country of women" and that they now account for over 70 percent of the population).

(5) See Human Rights Watch, Shattered Lives supra note 3, at 76 (describing a Kigali doctor's account of treating a two-year old girl for chronic vaginitis as a result of being raped during the genocide); see also id. at 58 (describing one survivor's account of being repeatedly raped and held hostage at age eleven during the genocide).

(6) See id. at 24 (asserting that "rape was the rule and its absence the exception") (quoting Rene Degni-Segui, United Nations Special Rapporteur on Rwanda).

(7) See Kelly D. Askin, War Crimes Against Women: Prosecution in International War Crimes Tribunals 2-99 (1997) (describing gender-based violence against women from 500 B.C. through World War II); see also Patricia Viseur-Sellers, The Context of Sexual Violence: Sexual Violence as Violations of International Humanitarian Law, in 1 Substantive and Procedural Aspects of International Criminal Law: The Experience of International and National Courts 263, 265 (Gabrielle Kirk McDonald & Olivia Swaak-Goldman eds., 2000) (stating that "[w]artime arsenals employed sexual violence as a standard armament for two thousand of the past twenty-five hundred years").

(8) See, e.g., Human Rights Watch, Women's Human Rights, in World Report 1999 427, available at [url]www.hrw.org/wr2k/Wrd.htm[/url] (last visited Jan. 11, 2003) (noting that the first conviction for rape at the ICTR demonstrated significant progress in denouncing sexual violence against female civilians).

(9) See International Crisis Group, The International Criminal Tribunal for Rwanda: Justice Delayed 1-3 (June 7, 2001), at [url]www.crisisweb.org/library/documents/report_archive/A400442_02102001.pdf[/url] (last visited Mar. 25, 2004) (reporting that the organization's independent evaluation of the ICTR's first seven years of existence concluded that the Tribunal had failed to uphold its mandate). A majority of Rwandans were found to hold the belief that the ICTR is "a useless institution, an expedient mechanism for the international community to absolve itself of its responsibilities for the genocide and its tolerance of the crimes of the RPF [Rwandan Patriotic Front]." Id. at iii. See also David Stoelting et al., International Legal Developments in Review: International Criminal Tribunals for the Former Yugoslavia and Rwanda, 36 Int'l Law. 573, 578-81 (2002) (detailing the controversies and public embarrassment the ICTR faced in 2001 leading to its internal reorganization that year).

(10) See Kelly D. Askin, Sexual Violence in Decisions and Indictments of the Yugoslav and Rwandan Tribunals: Current Status, 93 Am. J. Int'l L. 97, 99 (1999) (emphasizing how in contrast to the Nuremberg and Tokyo Tribunals, which largely ignored gender-based crimes, the International Criminal Tribunal for the former Yugoslavia ("ICTY") and the ICTR have "surmounted reluctance and other obstacles to address these crimes despite their sexually graphic nature and traditional insensitivities to women's rights and needs").

(11) See Prosecutor v. Akayesu, Case No. ICTR-96-4-T, Judgement (Sept. 2, 1998), at [url]www.ictr.org/default.htm[/url] (last visited Apr. I0, 2004) (convicting Jean Paul Akayesu of crimes against humanity and genocide).

(12) See Prosecutor v. Akayesu, Case No. ICTR-96-4-I, Amended Indictment (June 1997), paras. 2-4, at [url]www.ictr.org/ENGLISH/cases/Akayesu/indictment/actamond.htm[/url] (last visited Mar. 3, 2004) (explaining the relative position and authority of bourgmestres in Rwanda). Rwanda is divided into eleven prefectures each governed by a prefect and subdivided into communes, which are governed by bourgmestres or mayors. Id. para. 2. Bourgmestres are appointed by the President of the Republic, upon recommendation of the Minister of the Interior. Id. "In Rwanda, the bourgmestre is the most powerful figure in the commune. His de facto authority in the area is significantly greater than that which is conferred upon him de jure." Id. Jean Paul Akayesu served as mayor of the Taba commune from April 1993 until June 1994. Id. para. 3. His responsibilities included "performance of executive functions and the maintenance of public order within his commune, subject to the authority of the prefect. He had exclusive control over the communal police, as well as any gendarmes put at the disposition of the commune. He was responsible for the execution of laws and regulations and the administration of justice, also subject only to the prefect's authority." Id. para. 4.

(13) See id. paras. 12A-12B (adding counts thirteen and fourteen against Akayesu for committing crimes against humanity by facilitating the commission of sexual violence (rape and other inhumane acts) at the bureau communal he headed). The amended indictment also added a definition of sexual violence. Id. para. 10A.

(14) See, e.g., Press Release, Amnesty International, Rwanda: Amnesty International Welcomes Historic Rulings of the International Criminal Tribunal for Rwanda, Sept. 4, 1998, at [url]www.amnestyusa.org/news/1998114703098.htm[/url] (last visited Mar. 26, 2004) (explaining that Akayesu's conviction was the first time an international court had applied the Genocide Convention of 1948).

(15) See A Landmark Ruling on Rape, N.Y. Times, Feb. 24, 2001, at A12 (reporting that mass rape in Rwanda was ignored during the first four years of the ICTR's existence, and that vigorous lobbying from women's groups and the encouragement by the sole female judge at the Tribunal forced investigators to look into rape and hire more female investigators).

(16) See Human Rights Watch, Shattered Lives, supra note 3, at 5 (asserting that an international legal framework condemning genocide and holding the perpetrators accountable will send a message "that impunity for such crimes will not be tolerated by the international community").

(17) See, e.g., Human Rights Watch, Women's Rights Division Home Page, at [url]www.hrw.org/women/index.php[/url] (last visited May 29, 2004) ("Combatants and their sympathizers in conflicts, such as those in Sierra Leone, Kosovo, the Democratic Republic of Congo, Afghanistan, and Rwanda, have raped women as a weapon of war with near complete impunity."). Although the international women's human fights movement has made "very real progress [in] identifying, raising awareness about, and challenging impunity for women's human rights violations," violations against women's rights remain "relentless, systematic, and widely tolerated, if not explicitly condoned." Id. See generally Tiare Rath, In War-Riddled Congo, Militias Rape With Impunity, Women's eNews, Apr. 27, 2003, at [url]www.womensenews.org/article.cfm/dyn/aid/1307/context/archive/[/url] (last visited Apr. 10, 2004) (reporting that the type of rape warfare experienced by Rwandan women is also being inflicted on women and girls in the Democratic Republic of Congo, which has been embroiled in a five-year armed conflict).

(18) Cf. Catharine MacKinnon, Reflections on Sex Equality Under Law, 100 Yale L.J. 1281, 1284 (1991) ("Determined to leave a trace, to make sex equality ordinary, to live under social conditions that reflect and reinforce their aspirations rather than suppress or extinguish them, to live in respect and safety rather than indignity and terror, to redefine social standards in the image of their values, to participate fully in their own times, to save their own lives and those of generations to come, women have long demanded legal change as one vehicle for social change.").

(19) See Hilary Charlesworth, What are Women's International Human Rights?, in Human Rights of Women: National and International Perspectives (Rebecca Cook ed., 1994) (referencing the international community's past failure to include women in the interpretation, implementation, and enforcement of basic human rights).

(20) See Askin, supra note 10 and accompanying text (asserting the failure of the post-World War II tribunals to prosecute rape as a serious war crime); see also Catharine MacKinnon, Rape, Genocide, and Women's Human Rights, 17 Harv. Women's L.J. 5, 5 (1994) (arguing that "human rights have not been women's rights--not in theory or reality, not legally or socially, not domestically or internationally").

(21) See MacKinnon, supra note 20, at 5 (reporting that women are violated sexually and reproductively every day in every country in the world); see also Human Rights Watch, Shattered Lives, supra note 3, at 27 (attesting that rape against countless women and young gifts throughout history is a bitter reality in all regions of the world).

(22) See Report of the Fourth World Conference on Women, U.N. Doc. A/CONF.177/20/Rev.I (Sept. 4-15, 1995), para. 113, available at [url]www.un.org/[/url] womenwatch/confer/beijing/reports/ (last visited Apr. 10, 2004) (describing gender-based violence as actions, threats of action, coercion, or arbitrary deprivation of liberty that results in or is likely to result in physical, sexual, or psychological harm or suffering). Gender-based violence also includes, but is not limited to the following:

(a) Physical, sexual and psychological violence occurring in the
family, including battering, sexual abuse of female children in the
household, dowry-related violence, marital rape, female genital
mutilation and other traditional practices harmful to women,
non-spousal violence and violence related to exploitation; (
Physical, sexual and psychological violence occurring within the
general community, including rape, sexual abuse, sexual harassment
and intimidation at work, in educational institutions and
elsewhere, trafficking in women and forced prostitution; (c)
Physical, sexual and psychological violence perpetrated or
condoned by the State, wherever it occurs.
Id.

(23) See Report of the Secretary-General on Women, Peace and Security, U.N. SCOR, 57th Sess., para. 6, U.N. Doc. S/2002/1154 (2002) (explaining how women are disproportionately targeted in armed conflicts and constitute the majority of all victims, refugees, and internally displaced persons). Because women do not enjoy equal status with men in any society, armed conflict exacerbates inherent discrimination against women in violent forms, Id. para. 5. During conflict, women and young girls are vulnerable to all forms of gender-based violence, including sexual violence, exploitation, torture, rape, mass rape, forced pregnancy, sexual slavery, enforced prostitution, and trafficking, Id. para. 7. Often the highest level of officials endorses such acts and attributes political significance to them. Id. See also Human Rights Watch, Women's Human Rights, supra note 8, at 429 (emphasizing how being female is a risk factor because women and girls are often persecuted by using sexual violence against them on the basis of their gender); see generally Vesna Kesic, From Reverence to Rape: An Anthropology of Ethnic and Genderized Violence, in Frontline Feminisms: Women, War, and Resistance 23, 25 (Marguerite R. Waller & Jennifer Rycenga eds., 2000) (asserting that violence against women in armed conflict varies "in form, scale, and intensity from killing, rape, torture, forced impregnation, body searches at checkpoints, imprisonment, settlement in concentration camps and refuges, and forced prostitution to verbal insults and degradation, psychological suffering for losses, and the burden of responsibility that women carry as survivors").

(24) See William F. Felice, Taking Suffering Seriously: The Importance of Collective Human Rights 99 (1996) (explaining how norms and values "can create a countervailing force to other components of power, including the military and economic components").

(25) See Declaration on the Protection of Women and Children in Emergency and Armed Conflict in 1974, G.A. Res. 3318, U.N. GAOR, 29th Sess., Supp. No. 31, para. 4, U.N. Doc. A/9631 (1974) (stressing the importance of special protection for women in armed conflict due to their role as mothers and caregivers). In 1976, the United Nations launched its "Decade for Women." See Report of the Fourth World Conference on Women supra note 22, para. 25 (describing how the U.N. General Assembly's "International Women's Year" in 1975 was a turning point in awareness of women's issues in the international community and began the U.N. Decade for Women (1976-85), which was a world-wide effort to examine the status and rights of women). Next, the United Nations created the Convention on the Elimination of All Forms of Discrimination Against Women, which is the main human rights instrument to monitor the status of women around the world. See Convention on the Elimination of All Forms of Discrimination Against Women, opened for signature Dec. 18, 1979, arts. 1-2, 12 U.N.T.S. 13, 13 (entered into force Sept. 3, 1981) (creating a monitoring committee of experts to review periodic reports made by States Parties evaluating compliance with obligations to abolish discriminatory laws and promote the status of women). In 1985 at the World Conference on Women in Nairobi, the United Nations adopted Forward Looking Strategies for Advancement of Women, which referred to specific abuses against women during armed conflict. See Report of the World Conference to Review and Appraise the Achievements of the United Nations Decade for Women: Equality, Development and Peace, U.N. GAOR, 40th Sess, para. 41, U.N. Doc. A/CONF.116128/Rev.1 (1986) (describing the progress of the last decade and specific goals that need further development in establishing full protection for women's human rights). Although the United Nations' nominal "Decade for Women" ended in 1985, the organization kept abreast of gender issues in the international community and passed the Declaration on the Elimination of Violence Against Women in 1993. See Declaration on the Elimination of Violence Against Women, G.A. Res. 48/104, U.N. GAOR, 48th Sess., Supp. No. 49, at 217, U.N. Doc. A/48/49 (1993) (addressing explicitly gender-based violence in armed conflict). In 1994, the World Conference on Human Rights in Vienna passed the Vienna Convention, which specifically addressed gender issues. See Vienna Declaration and Programme of Action, World Conference on Human Rights, U.N. Doc. A/Conf.157/24 (1993) (explaining steps that should be taken to ensure that states give equal consideration to women's human rights in their domestic programs). The Fourth World Conference on Women in Beijing in 1995 produced the Beijing Declaration. See also Lisa A. Crooms, Using a Multi-Tiered Analysis to Reconceptualize Gender-Based Violence Against Women as a Matter of International Human Rights, 33 New Eng. L. Rev. 881,885 (1999) (enumerating the three main functions of the Violence Declaration). But see Hilary Charlesworth, The Mid-Life Crisis of the Universal Declaration of Human Rights, 55 Wash. & Lee L. Rev. 781, 794 (1998) (noting that "[t]he overarching slogan of the U.N. human rights system with respect to women seems to be just 'add women and stir.'" (quoting Christine Chinkin, Feminist Interventions Into International Law 19 Adel. L. Rev. 13, 18 (1997))).

(26) See Felice, supra note 24, at 110 (asserting that the international system provides standards upon which to judge state conduct and creates a dynamic process using principles to guide, judge, and influence state behavior).

(27) See Human Rights Watch, Shattered Lives, supra note 3, at 27-28 (quoting Radhika Coomaraswamy, the U.N. Special Rapporteur on Violence Against Women).

(28) See Amnesty International, Human Rights are Women's Right 18-20 (1995) (noting that Crusaders raped women in the name of religion in the twelfth century; invading forces mass-raped indigenous women in the fifteenth-century conquest of the Americas; English soldiers systematically raped Scottish women in the eighteenth century; the German army used rape as a weapon of terror in World War I; the Soviet army used rape as a weapon of revenge in World War II; and that Kuwaiti women and foreign domestic workers were subjected to sexual violence by Iraqi soldiers during Iraq's 1991 invasion of Kuwait); see also Iris Chang & William C. Kirby, The Rape of Nanking: The Forgotten Holocaust of World War II 2 (1998) (noting that Pakistani soldiers in trying to repress Bengalese nationalism in the 1971 civil war carried out the largest systematic rape of female civilians in humankind's history, but that this episode was only slightly larger than the systematic rape carried out in Nanking, China by Japanese soldiers from 1937-38).

(29) See Human Rights Watch, Shattered Lives, supra note 3, at 28 (explaining that the classification of rape and other forms of sexual violence as an attack of honor fails to recognize the acts as a violation of women's physical integrity, diminishes the serious nature of the crimes, and contributes to the misperception that rape is an incidental or lesser crime in comparison to crimes such as torture); see also Julie A. Mertus, War's Offensive on Women: The Humanitarian Challenge in Bosnia, Kosovo, and Afghanistan 73-75 (2000) (discussing how the definition of gender-based violence in international documents has evolved). Initially women were seen as chattel--i.e., property that belonged to men. Id. Soldiers viewed women as objects they could use as a reward for fighting or as compensation for being underpaid, Id. When rape was recognized as a crime, it was viewed as a crime against the man who possessed the woman--e.g., her husband or father. Id. Rape eventually came to be characterized as an attack against a woman's chastity or virtue, but this definition also denoted a crime against the man or family who was entitled to the woman's honor. Id.

(30) See Rhonda Copelon, Surfacing Gender: Reengraving Crimes Against Women in Humanitarian Law in Women and War in the Twentieth Century: Enlisted With or Without Consent 335 (Nicole A. Dombrowski ed., 1999) (describing the maintenance of concentration camp brothels for the rape of Jewish and Aryan women and the Allied soldiers' rape of German women).

(31) See supra notes 27-30, infra notes 32-42 and accompanying text (discussing how rape was not treated as a heinous atrocity during the tribunals following the Second World War).

(32) See Mertus, supra note 29, at 75-76 (describing that while the Nuremburg trials continued, the Allies established a second tribunal to prosecute Japanese officials for war crimes in 1946).

(33) See id. at 77 (describing the IMTFE tribunal's prosecution of rape).

(34) Id.

(35) See Jocelyn Campanaro, Women, War, and International Law: The Historical Treatment of Gender-based War Crimes, 89 Geo. L.J. 2557, 2565 (2001) (noting that the trials conducted under Control Council Law No. 10 were for lesser war criminals but allowed for the prosecution of a larger group of rapists, even though this did not become a reality).

(36) See Human Rights Watch, Shattered Lives, supra note 3, at 33 n.53 (explaining that the Nuremberg Charter, Article 6(c) was amended by the Berlin Protocol, 59 Stat. 1546, 1547 (1945), E.A.S. No. 472, 82 U.N.T.S. 284 to include rape as a crime against humanity).

(37) See Campanaro, supra note 35, at 2565.

(38) See Copelon, supra note 30, at 335 (explaining that the 1949 Geneva Conventions and the 1977 Protocols regarding the protection of civilians in war explicitly prohibit rape, forced prostitution, and any form of indecent assault, and call for special protection of women during war, including separate quarters with supervision and searches by women only).

(39) Geneva Convention Relative to the Protection of Civilian Persons in Time of War, Aug. 12, 1949, art. 27, 6 U.S.T. 3516, 75 U.N.T.S. 287 (entered into force Oct. 21, 1950) (defining rape as an attack on a woman's honor); Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims of International Armed Conflicts, June 8, 1977, art. 76, 1125 U.N.T.S. 3 (entered into force Dec. 7, 1978); Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims of Non-International Armed Conflicts, June 8, 1977, art. 4, 1125 U.N.T.S. 609 (entered into force Dec. 7, 1978) [hereinafter Additional Protocol II].

(40) See Copelon, supra note 30, at 336 (analyzing the negative implications of describing rape as a crime of honor).

(41) See id. (arguing that community stigmatization prevents women from reporting rape and therefore prevents legal prosecution of the crime).

(42) Id.

(43) See Campanaro, supra note 35, at 2566-69 (summarizing the post-World War II humanitarian law instruments and their treatment of crimes against women in armed conflict).

(44) See Human Rights Watch, Women's Human Rights, supra note 8, at 427 (discussing the importance of this precedent).

(45) See Mertus, supra note 29, at 71-81, 90-101 (referencing the historical treatment of gender in conflict, the treatment of gender-based violence under human rights laws, and the recognition of gender violence as a human rights violation); Campanaro, supra note 35, at 2566-69 (summarizing the international humanitarian law in place to protect women); see also Declaration on the Protection of Women and Children in Emergency and Armed Conflict in 1974, supra note 25 and accompanying text (assessing the United Nation's efforts in implementing norms to protect women's human rights).

(46) See supra note 4 and accompanying text.

(47) See Gerard Prunier, The Rwanda Crisis: History of a Genocide 211-12 (1995) (detailing the events leading up to the genocide). The party responsible for this event was largely uninvestigated and is still unknown. Id. at 213. See generally Des Forges, supra note 3 (discussing the events preceding the genocide).

(48) See Prunier, supra note 47, at 229 (describing how the Hutu government used the military during the genocide).

(49) See Human Rights Watch, Shattered Lives, supra note 3, at 65-68 (presenting individual testimony of the sexual violence Hutu women suffered during the genocide and noting that this occurred especially if they "looked Tutsi" or were married to a Tutsi).

(50) See id. at 42-65 (detailing individual testimony of the violence inflicted upon Tutsi women).

(51) See id. at 1, 48 (emphasizing that administrative, military, political, and civilian authorities at the national and local levels encouraged the systematic raping of women and children to further the goal of destruction of the Tutsi). In previous conflicts in Rwanda, women and children were generally protected as civilians; however, leaders of the genocide encouraged an organized strategy to rape as a tool of destruction. Id. at 41.

(52) See Daniel J. Steinbock, Interpreting the Refugee Definition, 45 UCLA L. Rev. 733, 785 (1998) (describing the void between normative creation and implementation of human rights and actual enforcement of those rights); see also Joshua Bardavid, The Failure of the State-Centric Model of International Law and the International Criminal Court 15 N.Y. Int'l L. Rev. 9, 10 (2002) (emphasizing the lack of an international rule of law to prevent atrocities and reporting that the former United Nations' High Commissioner for Human Rights commented that "a person stands a better chance of being tried and judged for killing one human being than for killing 100,000").

(53) See Human Rights Watch, Shattered Lives, supra note 3, at 1 (referencing the sexual violence Rwandan women experienced on a massive scale during the 1994 genocide and its aftermath); see generally Des Forges, supra note 3 (describing the events leading up to the genocide and the violence that occurred in specific areas in extensive detail).

(54) See Llezlie L. Green, Note, Gender Hate Propaganda and Sexual Violence in the Rwandan Genocide: An Argument For Intersectionality in International Law. 33 Colum. Hum. Rts. L. Rev. 733, 746-50 (2002) (asserting that propaganda dispersed by the Hutu government fueled gender-specific hate toward Tutsi women).

(55) See Human Rights Watch, Shattered Lives. supra note 3, at 15-19 (describing different propaganda messages directed at Tutsi women by the Hutu government). The images also portrayed Tutsi women as spies who would dominate and undermine Hutu men. Id. at 19.

(56) Cf Michelle J. Anderson, From Chastity Requirement to Sexuality License: Sexual Consent and a New Rape Shield Law, 70 Geo. Wash. L. Rev. 51, 66-69 (2002) (explaining the female virtue paradigm, where sexless or virtuous women are protected by society and women portrayed as sexual or those who have sexual histories are perceived as "unchaste and therefore subject to sexual abuse without legal redress").

(57) See Human Rights Watch, Shattered Lives, supra note 3, at 18 (using rape during the genocide shattered these images by "humiliating, degrading, and ultimately destroying the Tutsi woman"); see also MacKinnon, supra note 20, at 12 (describing genocidal rape as rape under orders, rape as massacre, rape to kill and make the victims wish they were dead). "It is also rape as an instrument of forced exile a rape to be seen and heard and watched and told to others: rape as a spectacle.... to drive a wedge through a community, to shatter a society, to destroy a people." Id. See generally Copelon, supra note 30, at 332, 338 (describing rape as one of the most common forms of torture used against women).

(58) See Human Rights Watch, Shattered Lives, supra note 3, at 72-75 (explaining how surviving rape results in stigma, isolation, and ostracization for many women and young girls).

(59) Id. at 25, 89-91 (describing rape as one of the most under-reported crimes).

(60) Id. at 24.

(61) See Copelon, supra note 30, at 333 (reporting that the Rwandan National Population Office confirmed that between 2,000 and 5,000 Rwandan women were pregnant as a result of being raped, but noting that not all rapes result in a full-term pregnancy).

(62) See Human Rights Watch, Shattered Lives, supra note 3, at 43-45 (detailing one woman's experience of multiple gang rapes and sexual mutilation at the hands of the Interahamwe).

(63) See id. at 79.

(64) See id. at 79-80.

(65) See id. at 79-82 (describing the psychological difficulties of becoming pregnant through rape). Children conceived from rape are known as "enfants non-desires" (unwanted children), "enfants de mauvais souvenir" (children of bad memories), or children of hate. Id. at 79. One Rwandan woman asked, "How can you have a child of someone who killed your husband and children?" Id.

(66) See Human Rights Watch, Shattered Lives, supra note 3, at 73-74 (noting comments of two widows interviewed). "Our past is so sad. We are not understood by society.... We become crazy. We aggravate people with our problems. We are the living dead." Id. at 73. "When they kill your husband and children and then leave you, it is like killing you. They left us to die slowly. I wish every day that I was dead." Id. at 74. But see id. at 75 (noting one survivor's desire to "challenge the [rapists/killers] and live. We don't want to remain the living dead.").

(67) See Landesman, supra note 2, at 89, 116 (summarizing the long-term consequences of surviving rape).

(68) See id. at 116. Rwandan President Kagame has asserted that the Hutu government brought AIDS patients out of hospitals to form "battalions of rapists." Id. In addition, thirty-five percent of the Rwandan army was reportedly HIV-positive. Human Rights Watch, Shattered Lives, supra note 3, at 76. See also Nicole Itano, How Rwanda's Genocide Lingers for Women, Christian Sci. Monitor, Nov. 27, 2002, available at [url]www.csmonitor.com/2002/1127/p08s01-woaf.html[/url] (last visited Apr. 10, 2004) (describing how a handful of programs are assisting women who were raped and infected with AIDS. but thousands more go without help); see generally Janice Alfred, The 45th Session of the Commission on the Status of Women: Gender Discrimination and the AIDS Pandemic, 18 N.Y.L. Sch. J. Hum. Rts. 439, 439 (2002) (reporting that HIV/AIDS is the fourth leading cause of death in sub-Saharan Africa and discussing its effect on women).

(69) See Human Rights Watch, Shattered Lives, supra note 3, at 47, 59 (describing women who believe surviving the genocide is more horrific than the crimes they suffered).

(70) Id. at 25.

(71) Id. at 47, 59.

(72) See id. at 24 (emphasizing rape as one of the most under-reported crimes due to the reluctance of survivors to seek medical attention or report their experiences during the genocide to anyone).

(73) See Landesman, supra note 2, at 82 (asserting that Nyiramasuhuko is the first women on trial for genocide in an international court); see also Nicole Hogg, Women Accused of Genocide in Rwanda. Women's Human Rights in Conflict Situations Newsletter (Int'l Centre for Hum. Rts. and Democratic Dev., Canada), vol. 4 (2001), at [url]www.ichrdd.ca/[/url] english/commdoc/publications/women/bulletin/ vol4no1/womenAccusedOfGenocideRwanda .html (last visited Mar. 26, 2004) (listing other female offenders who have been tried for genocide, not including rape). For example, two Rwandan nuns were convicted of genocide in Belgium, and six women charged with genocide in Rwandan courts received a death sentence with one being reduced to life imprisonment and one being executed. Id. See generally African Rights, Rwanda: Not So Innocent: When Women Become Killers (1995) (explaining the ways women participated in the genocide with detailed testimony against certain alleged women offenders).

(74) See Landesman, supra note 2, at 82-84 (giving a detailed account of the activities in Butare following Nyiramasuhuko's arrival).

(75) Id. at 82.

(76) Id.

(77) Id.

(78) See supra note 51 and accompanying text (describing how government officials sanctioned the sexual violence as part of the genocide).

(79) See, e.g., Michele Landsberg, Misplaced Blame: With Many Men Behind the Rwanda Atrocities, Why Does the Media Single Out a Woman as a Unique Monster, The Hamilton Spectator Mag., Sept. 28, 2002, 2002 WL 26714001 ("Nyiramasuhuko did not invent, plan or initiate the mass rapes alone. The Hutu government, of which she was a fanatically loyal servant, did that."); see generally Lucinda Joy Peach, Is Violence Male? The Law, Gender, and Violence, in Frontline Feminisms: Women, War, and Resistance, supra note 23, at 57, 62-64 (discussing theories behind the law's failure to condemn male violence against women). Peach asserts that the law is not only male-biased and itself violent, but the law also operates on the basis of an understanding that violence is male, which places women in a "double-bind" where violence exercised by legitimate agents--i.e., men--is not prohibited with the same vigor as it is for illegitimate agents, i.e., women, who use violence. Id.

(80) See Landesman, supra note 2, at 82 (noting that Interahamwe--the militia group who supported the Hutu government--means "those who attack together").

(81) Id.

(82) Id.

(83) See id. (describing how after obeying Nyiramasuhuko's orders, the Interahamwe dragged Tutsi women away to a forested area to be raped). The remaining refugees received machine-gun fire and grenades in the "sanctuary." Any surviving individuals met death by machete. Id. Nyiramasuhuko watched the entire episode until bulldozers began piling bodies for burial in a nearby pit. Id. at 84.

(84) See id. at 82 (describing how "Butare's Favorite Daughter" returned to massacre and incite sexual violence against Tutsis in Butare).

(85) See id. (reporting that witnesses reported that Interahamwe said they were tired from killing all day, so instead of raping them they "just put the gasoline in bottles and scattered it among the women, then started burning").

(86) See Lindsey Hilsum, Rwanda--Refugees and Genocidaires, in Crimes of War: What the People Should Know 316-18 (Roy Gutman et al. eds., 1999), available at [url]www.crimesofwar.org/thebook/book.html[/url] (last visited May 3, 2004) (describing the inexplicable failure to arrest Nyiramasuhuko despite that she was one of the most easily identifiable members of the Rwanda government).

(87) Compare Landesman, supra note 2, at 85 (reporting that she found safety in a refugee camp in Congo, eventually slipping into Kenya, where she lived as a fugitive for almost three years), with Hilsum, supra note 86, at 317 (reporting that she escaped to Zaire through the Zone Turquoise controlled by French forces). Hilsum also reports that while at a refugee camp in eastern Zaire near Bukavu, she was employed by a Catholic relief organization as a social services coordinator. Id. She reportedly traveled undisturbed between Zaire and Kenya for three years until the current Rwandan government pressured President Moi for her capture. Id.

(88) See Prosecutor v. Nyiramasuhuko, Case No. ICTR-97-21-I, Amended Indictment, (Aug. 10, 1999), at [url]www.ictr.org/ENGLISH/cases/Nyira/indictment/index.pdf[/url] (last visited Apr. 10, 2004) (naming charges for inciting rape under counts 7 and 11).

(89) See Prosecutor v. Akayesu, Case No. ICTR-96-4-I, Amended Indictment (June 1997), para. 12, at [url]www.ictr.org/ENGLISH/cases/Akayesu/indictment/actamond.htm[/url] (last visited Mar. 3, 2004) (asserting that at least 2,000 Tutsis were killed in Taba between April 7 and the end of June 1994).

(90) See id. paras. 2, 12 (explaining that the President of the Republic appoints each bourgmestre who is the most powerful official in the commune). As bourgmestre, Akayesu also had exclusive control of the communal police force. Id. para. 4.

(91) See id. para. 12 (describing his official duties).

(92) Id.

(93) See Amnesty International, supra note 14, at 1 (describing the extensive sexual violence and massacres that occurred at the Taba commune under Akayesu's control).

(94) See Akayesu, Case No. ICTR-96-4-I, at paras. 12A-12B (describing the sexual violence suffered at the Taba commune).

(95) Id.

(96) Id.

(97) Id.

(98) See Olivia Swaak-Goldman, Crimes Against Humanity, in 1 Substantive and Procedural Aspects of International Criminal Law: The Experience of International and National Courts, supra note 7, at 145 (explaining that crimes against humanity are considered among the most serious war crimes); see also Theodor Meron, Rape as a Crime under International Humanitarian Law, 87 Am. J. Int'l L. 424, 426-28 (1993) (explaining how rape could be considered a crime against humanity under international law).

(99) See Diane F. Orentlicher, Settling Accounts: The Duty to Prosecute Human Rights Violations of a Prior Regime, 100 Yale L.J. 2537, 2595 (1991) (noting that laws proscribing crimes against humanity have commanded commitment by the international community, which has "resolved emphatically that it will not countenance impunity for massive atrocities against persecuted groups").

(100) See Askin, supra note 7, at 300 (expressing the improbability of successfully prosecuting sexual assault as a crime against humanity under Article 5); see also Orentlicher, supra note 99, at 2590-91 and nn.238-40 (asserting that most post-Nuremberg efforts to broaden the scope of crimes against humanity have "failed to garner broad consensus").

(101) See Patricia M. Wald, Judging War Crimes, 1 Chi. J. Int'l L. 189, 191 (2000) (noting that the ICTR and ICTY have both "spawned over 300 articles in the international journals, more than any other topic in international law in the last decade").

(102) See Amnesty International, supra note 14 and accompanying text (describing the significance of the Akayesu decision in linking sexual violence to crimes against humanity and genocide).

(103) See id. (arguing that the Akayesu decision sends a clear message to the international community that genocide will not be tolerated).

(104) Statute of the International Criminal Tribunal for the Prosecution of Persons Responsible for Genocide and Other Serious Violations of International Humanitarian Law Committed in the Territory of Rwanda and Rwandan Citizens Responsible for Genocide and Other Such Violations Committed in the Territory of Neighboring States, Between January 1, 1994 and December 31, 1994, S.C. Res. 955, U.N. SCOR, 49th Sess., Annex, 3453d mtg., U.N. Doc. S/RES/955 & Annex (1994), reprinted in 33 I.L.M. 1958 (1994) [hereinafter ICTR Statute].

(105) See Panel, Violence Against Women and International Law: Rape as a War Crime, 90 Am. Soc'y Int'l L. Proc. 605, 613 (Patricia Viseur-Sellers noting that because no previous war tribunal or convention explicitly defined rape, the Prosecutor's Office submitted the elements of the crime of rape as prohibited conduct under the grave breaches concept and under the crimes against humanity concept in the spring of 1996, almost one year before amending the Akayesu indictment).

(106) See Barbara Crossette, An Old Scourge of War Become its Latest Crime, N.Y. Times, June 14, 1998, at 2 (explaining that pressure from women's organizations and the support of then Prosecutor Richard Goldstone succeeded in elevating sex crimes to the level of genocide and crimes against humanity).

(107) See also Patricia Viseur-Sellers, The Cultural Value of Sexual Violence, 93 Am. Soc'y Int'l L. Proc. 312, 312 (1999) (discussing the prosecutor's decision to amend Akayesu's indictment to include sexual violence charges).

(108) See Crossette, supra note 106, at 2 (alluding to the need to ensure better prosecution of gender-based violence so pressure from women's groups is no longer a prerequisite to amending indictments).

(109) In 1994, the United Nations created the ICTR as an ad hoc tribunal to adjudicate crimes committed by individuals through a resolution passed by the U.N. Security Council. International Criminal Tribunal for Rwanda. See ICTR, About the ICTR: General Information, at [url]www.ictr.org/default.htm[/url] (last visited Mar. 3, 2004). The ICTR has jurisdiction over crimes committed "by Rwandans in the territory of Rwanda and in the territory of neighbouring States, as well as non-Rwandan citizens for crimes committed in Rwanda" during the year 1994. Id. The official mission of the ICTR is to "render justice and aid reconciliation in Rwanda establishing the historical truth of what happened in Rwanda in 1994." Id. The ICTR consists of three major organs: the Chamber, which includes the Appeals Chamber and Trial Chambers; the Prosecutor's Office, which is responsible for investigating and prosecuting; and the Registry, which is responsible for the overall administration and management of the Tribunal. Id. In addition, there exists the Defense Counsel Management Section, the Detention Facility, and the Witnesses and Victims Support Section. Id. The Prosecutor's Office is located in Kigali, Rwanda, and the seat of the ICTR is in Arusha, Tanzania. Id. In 2002-03, the ICTR had a budget of $177,739,400 and 872 staff members from eighty countries. Id. The ICTY is substantively similar but was created in 1993 to adjudicate crimes committed by individuals in the former Yugoslavia beginning in 1991. See generally International Criminal Tribunal for the former Yugoslavia, The ICTY at a Glance: General Information, at [url]www.un.org/icty/glance/index.htm[/url] (last visited Mar. 3, 2004) (providing an overview of the ICTY's structure and jurisprudence).

(110) See, e.g., Nancy Amoury Combs, International Criminal Jurisprudence Comes of Age: The Substance and Procedure of an Emerging Discipline, 42 Harv. Int'l L.J. 555, 560-61 (2001) (concluding that the ICTR's judgments on genocide have greatly enhanced the understanding of the crime's elements). The work of both ad hoc tribunals has greatly influenced accountability under international humanitarian law and led to the development of the Special Court for Sierra Leone. See About the ICTR: General Information: Achievements of the ICTR, at [url]www.ictr.org/default.htm[/url] (last visited Mar. 3, 2004). Suggestions for similar tribunals are now common responses to gross human rights violations in the Democratic Republic of Congo, Cambodia, and East Timor. Id.

(111) See Eighth Annual Report of the ICTR for the Prosecution of Persons Responsible for Genocide and Other Serious Violations of International Humanitarian Law Committed in the Territory of Rwanda and Rwandan Citizens Responsible for Genocide and Other Such Violations Committed in the Territory of Neighbouring States between January 1 and December 31, 1994, U.N. GAOR, para. 1, U.N. Doc. S/2003/707 (2003), available at [url]www.ictr.org[/url] (last visited Mar. 3, 2004) [hereinafter Eighth Annual Report] (providing a detailed overview of the completed judgments and those the Tribunal expects to complete in the near future noting that two trials involving ten accused, the Butare case [Nyiramasuhuko] and the Military case, were in progress at the time of the report). During the first mandate from 1994-99, the Tribunal issued six judgments involving seven accused. Newly Elected President Erik Mose Addresses Staff, ICTR Newsletter Vol. I, No. 2, at 1 (July 2003), available at [url]www.ictr.org/ENGLISH/newsletter/july03/july03.pdf[/url] (last visited Mar. 3, 2004). During the second mandate from 1999-2003, the Tribunal "doubled [its] judicial output." Id. The third mandate began in 2003 and should conclude in 2008. Id. The justice is slow and one detainee has been in custody since 1999, while several others since 2000. See Eighth Annual Report, supra, para. 80. A total of thirty-one accused are awaiting trial at the detention facility with several more accused still at large. Id. But see Newly Elected President Erik Mose Addresses Staff, supra (statements by President Mose reminding the audience that when the Tribunal began its work judges worked by candlelight and there were no tarmac roads in Arusha and only limited supplies, so in retrospect "[t]he improvements from May 1999 to May 2003 have been amazing").

(112) See Symposium, War Crime Tribunals: The Record and the Prospects: The Contribution of Ad Hoc Tribunals in International Humanitarian Law, 13 Am. U. Int'l L. Rev. 1509, 1531 (1998) [hereinafter The Contribution of Ad Hoc Tribunals] (Patricia Viseur-Sellers stating that the International Court of Justice and the European Court for Human Rights cite the jurisprudence of the tribunals). See also id. at 1532 (W. Hays Parks explaining that the tribunals' decisions are absolute "gold mines of information" and assist very substantially in drafting the U.S. Joint Services Law of War Manual); id. at 1536 (Robert K. Goldman noting "[w]e routinely review the cases decided by the Tribunal and cite its jurisprudence in new decisions of the [Inter-American Commission on Human Rights]").

(113) See generally The International Court of Justice, General Information: The Court at a Glance, at 212.153.43.18/ icjwww/igeneralinformation/icjgnnot.html (last visited Mar. 3, 2004). The International Court of Justice ("ICJ") is unique from the ad hoc tribunals because it resolves conflicts between states. Id. It is the principal judicial organ of the United Nations and derives its authority from the U.N. Charter. Id. It was created in 1946 to replace the Permanent Court of International Justice and is located in The Hague, Netherlands. Id.

(114) See The Contribution of Ad Hoc Tribunals, supra note 112 and accompanying text (describing how members of the international community are using the ICTR precedent).

(115) See Rape and Genocide in Rwanda: The ICTR's Akayesu Verdict, Teaching Human Rights Online, at homepages.uc.edu/thro/rw/ (last visited May 3, 2004) (describing the significance of the Akayesu verdict). The ICC is unique because it is an independent body that adjudicates crimes committed by individuals, whereas the ICJ and the two ad hoc tribunals operate within the U.N. framework. See International Criminal Court, Historical Introduction, at [url]www.icc-cpi.int/php/show.php?id=history[/url] (last visited Mar. 3, 2004). In 1998, the ICC was created by the Rome Statute, which entered into force in 2002. Id. The court's general mission is to secure universal respect for human rights and fundamental freedoms of individuals through the prosecution of individuals for war crimes. Id. See also Press Release, First Anniversary of the Court, International Criminal Court, at [url]www.icccpi.int/library/newspoint/[/url] mediaalert/kit_1_year.doc (last visited Mar. 3, 2004).

(116) See Lawrence v. Texas, 539 U.S. 558, 573 (2003) (citing the European Convention on Human Rights in support of its decision to invalidate all state laws in the United States criminalizing same-sex sexual conduct); Grutter v. Bollinger, 539 U.S. 306, 344 (2003) (Ginsburg, J., concurring) (citing the International Convention on the Elimination of All Forms of Racial Discrimination to support the majority's decision, which held that diversity is a compelling state interest, but durational limits should exist for affirmative action programs); see also Kadic v. Karadzic, 866 F. Supp. 734 (S.D.N.Y. 1994), rev'd by 70 F.3d 232 (1995) (holding individuals responsible domestically for international war crimes by basing subject matter jurisdiction on the Alien Tort Claims Act, 28 U.S.C. [section] 1350, and the Torture Victim Protection Act of 1991, 28 U.S.C. [section] 1331); see generally Douglass Cassel, The ICC's New Legal Landscape: The Need to Expand U.S. Domestic Jurisdiction to Prosecute Genocide, War Crimes, and Crimes Against Humanity, 23 Fordham Int'l L.J. 378, 381-87 (1999) (positing that a lack of appropriate domestic jurisdiction and substantive legislation contributes to the inability of the U.S. courts to prosecute genocide and crimes against humanity).

(117) Compare Prosecutor v. Akayesu, Case No. ICTR-96-4-T, Judgement (Sept. 2, 1998), at [url]www.ictr.org/default.htm[/url] (last visited Apr. 10, 2004), paras. 733-34 (excluding the nonconsensual requirement from the definition of rape), with George E. Burns, Jr., Rape, Consent & Force: Legal Mystery--Modern Problem, 34 Md. B.J. 44, 44 (2001) (noting that in Maryland, for example, second-degree rape requires the prosecution to prove: (1) that the defendant had vaginal intercourse with the victim; (2) that the act was committed by force or threat of force; and (3) that the act was committed without the consent of the victim).

(118) See Viseur-Sellers, supra note 107, at 312 (describing how the Akayesu decision is "singularly significant" in advancing sexual violence jurisprudence in international law); Askin, supra note 10, at 109 (describing the progressive language of the Akayesu decision).

(119) See Akayesu, Case No. ICTR-96-4-T, para. 687.

(120) Id.

(121) Id.

(122) Id. para. 688.

(123) Id.

(124) Kristen Boon, Rape and Forced Pregnancy under the ICC Statute: Human Dignity, Autonomy, and Consent, 32 Colum. Hum. Rts. L. Rev. 625, 647 (2001).

(125) See Michelle J. Anderson, Reviving Resistance in Rape Law, 1998 U. Ill. L. Rev. 953, 1000-01 & nn.280-84 (1998) (reviewing definitions for rape in the criminal statutes of all fifty U.S. states and the District of Columbia).

(126) See Prosecutor v. Akayesu, Case No. ICTR-96-4-I, Amended Indictment (June 1997), para. 10A (describing the forced nudity Hutus inflicted upon Tutsis at the Taba police bureau).

(127) See Akayesu, Case No. ICTR-96-4-T, paras. 731, 733-34 (enumerating the requirements for genocidal intent).

(128) Id. para. 734.

(129) See Landesman, supra note 2, at 116 (explaining that intentional HIV infection is murder because it intends to annihilate the procreators and perpetuate death unto the next generation so that the killing continues).

(130) See Prosecutor v. Furundzija, Judgment, IT-95-17/1, paras. 175, 179-85, 273 (Dec. 10, 1998), at [url]www.un.org/icty/furundzija/trialc2/judgement/fur-tj981210e.pdf[/url] (last visited Mar. 26, 2004) (finding Furundzija guilty of aiding and abetting the rape and sexual assault on a woman even though he was not physically present during the actual assault based on the grounds that his "presence and continued interrogation of [the woman] encouraged Accused B and substantially contributed to the criminal acts committed by him."). This was the first decision issued by a U.N. tribunal convicting someone of rape as a war crime. Associated Press & Reuters, War Crimes Tribunal Convicts Bosnian Croat of Rape, at [url]www.cnn.com/WORLD/europe/9812/10/bosnia.war.crimes/[/url] (last visited Mar. 3, 2004).

(131) Furundzija, IT-95-17/1, para. 185.

(132) See Boon, supra note 124, at 644-45.

(133) See id. ("While the ICC approach most closely resembles the [ICTY definition], all three formulations were apparent during the negotiations and are thus relevant to an understanding of the ICC elements of rape.").

(134) See id.

(135) Preparatory Comm'n for the Int'l Crim. Ct., Elements of Crime, arts. 7(1)(g)-1(1) n.16, 8(2)((xxii)-1(1) n.51, available at [url]www.un.org/law/icc.statute/elements/English/[/url] (last visited Nov. 16, 2003) [hereinafter Elements of Crime].

(136) See Boon, supra note 124, at 649.

(137) See Elements of Crime, supra note 135.

(138) See Human Rights Watch, Women's Human Rights, supra note 8, at 440.

(139) See Amnesty International, supra note 14, at 1 (emphasizing the significance of the Akayesu decision).

(140) See Akayesu, Sentence, Case No. ICTR-96-4-T (Oct. 2, 1998), at [url]www.ictr.org/default.htm[/url] (last visited May 3, 2003) (listing his sentences for nine out of fifteen counts, which included three life sentences, four fifteen-year terms, and two ten-year terms, all to run concurrently); see also Akayesu, Appeals Chamber Judgment, Case No. ICTR-96-4-T (June 1, 2001), at [url]www.ictr.org/default.htm[/url] (last visited May 3, 2004) (affirming Akayesu's judgment and sentence).

(141) See Mary Margaret Penrose, Lest We Fail: The Importance of Enforcement in International Criminal Law, 15 Am. U. Int'l L. Rev. 321, 374 (1999) (noting that unlike the Rwandan national court system, the Tribunal cannot execute criminals).

(142) See Crossette, supra note 106, at 2 and accompanying text (asserting that the Akayesu indictment would not have been amended to include sexual charges without pressure from women's organizations); see also Human Rights Watch, Shattered Lives, supra note 3, at 94 (stating that in 1996 Human Rights Watch concluded that if the ICTR continued in its current manner, "it may fail to mount even one rape prosecution"); see generally MacKinnon, supra note 20, at 8 ("Women have created the idea that women have human rights out of a refusal to believe that the reality of violation we live with is what it means for us to be human--as our governments seem largely to believe.").

(143) See Askin, supra note 10 and accompanying text (describing the failure of the post-World War II tribunals to prosecute rape as a serious war crime).

We've accepted your thesis. Thank you and welcome to Hollywood Upstairs Political Science College.

Jesus Fuckin' Christ
Can i get the book from the library or do i have to read all of that here?

Look, buster, all I'm saying is we could be using this section to educate each other. Read the first couple paragraphs and then, if you're interested, do your own research.