Showing posts with label Catharine A. MacKinnon. Show all posts
Showing posts with label Catharine A. MacKinnon. Show all posts

On September 26

On this day in ...
... 1946, Andrea Dworkin (left) was born in Camden, New Jersey. Some time after earning a bachelor's degree in literature in 1968 from Bennington College, she moved to Europe and "married a Dutch political radical." (photo credit) The couple divorced within 3 years; Dworkin later told The New York Times:

'I was a battered wife, and pornography entered into it. Both of us read it, and it helped give me the wrong idea of what a woman was supposed to be for a man.'

Dworkin became a "feminist writer and antipornography campaigner," cowriting with Catharine A. MacKinnon an antipornography ordinance that would be invalidated on 1st Amendment grounds. Among Dworkin's books were Woman Hating (1974), Pornography: Men Possessing Women (1981), Intercourse (1987), and Heartbreak: The Political Memoir of a Feminist Militant (2002). Dworkin died in her sleep, at age 58, in 2005.


(Prior September 26 posts are here, here, and here.)

UN Women: Symbolism or Agent for Change?

As noted by IntLawGrrl Stephanie Farrior here, it was announced this week that former Chilean President, Michelle Bachelet (left) is the new UN Under-Secretary General and will lead the UN Entity for Gender Equality and the Empowerment of Women, known as UN Women. In this post I want to both outline the structure of the agency and consider why such an agency is required within the UN. While the establishment of UN Women is to be welcomed, questions necessarily arise as to whether or not it will stand as a symbolic commitment to gender equality and the advancement of women and girls or whether (as I hope will be the case) it will really operate as an agent for change to improve the lot of women and girls around the world.
The UN General Assembly -- which, as IntLawGrrl Amy Senier then reported, had adopted a resolution in this regard about a year ago -- established UN Women in July, as part of the organisation’s ongoing reform agenda. Described on its website as “an historic step in accelerating the Organization’s goals on gender equality and the empowerment of women”, UN Women is a new agency that merges four UN organisations: the Division for the Advancement of Women, the International Research and Training Institute for the Advancement of Women, the Office of the Special Adviser on Gender Issues and Advancement of Women, and the UN Development Fund for Women. Bringing these organisations together, UN Women will not only help to co-ordinate the work undertaken within the organisations but will also constitute a large and broad-ranging internal agency of the UN that can impact on the organisation’s wide range of work.
The establishment of UN Women will not, as far as I can tell, result in gender experts within different parts of the UN from being appointed (such as Professor Catharine MacKinnon’s role as Special Gender Adviser to the Prosecutor of the International Criminal Court); neither does it preclude the appointment of special rapporteurs to consider gender aspects of particular issues under consideration by the UN where this is thought appropriate. It should therefore be seen as a consolidation and, indeed, expansion of the gender equality mechanisms within the UN.
According to its website, UN Women has three stated aims:
► To support inter-governmental bodies, such as the Commission on the Status of Women, in their formulation of policies, global standards and norms;
► To help Member States to implement these standards, standing ready to provide suitable technical and financial support to those countries that request it and to forge effective partnerships with civil society; and
► To hold the UN system accountable for its own commitments on gender equality, including regular monitoring of system-wide progress.
This marks an important further step in the full integration of women and, indeed, more generally of gender-consciousness into the work of the United Nations.
The exclusion of women from the originating processes of international law and of the United Nations has been extensively commented on elsewhere, most authoritatively perhaps by Hilary Charlesworth, an IntLawGrrls guest/alumna, and Christine Chinkin in their immensely important monograph on The Boundaries of International Law: A Feminist Analysis (2000). Excluding women from the founding processes of the United Nations resulted in a lack of perspective on the distinctive and particular ways that laws, states and inter-state relationships can impact on women and girls. It also resulted in the occlusion for a long period of time from human rights law of the realities of women’s experiences. This was not exclusive to human rights law, of course; women were traditionally excluded from essentially all areas of international law and interested readers will find the Charlesworth & Chinkin analysis illuminating and, perhaps, depressing. The focus of this post, however, is on human rights law.
While it is of course true that women and girls do not exclusively experience gender-based violence, sexual violence, discrimination and exclusion, it is equally true to acknowledge that women and girls experience these conditions more than men and boys do and that this is related to persistent and pervasive social and legal conditions that disadvantage women. The UN human rights system cannot be accused of having remained in its ‘original’ masculine state; it has over time developed a number of agencies, resolutions, institutions and Conventions that focus specifically on the conditions of life as they are experienced by women. This has been an especial focus of the UN Convention on the Elimination of All Forms of Discrimination against Women and its enforcement mechanisms, but also by a commitment (met to a greater or lesser extent in different situations) to consider the impact of policies, laws and conditions on women and girls. However, CEDAW is not enough on its own: not only is CEDAW not universally ratified and implemented in domestic law, but the extent to which States have entered reservations to important (if not in fact foundational) provisions within the Convention has long been a source of comment.
In addition, an enormous international organisation such as the United Nations is in need of a gender perspective—if not a kind of internal gender watchdog—as is any state or large organisation. It is therefore entirely fitting that UN Women would commit, as it does, to holding “the UN system accountable for its own commitments on gender equality”. This will include not only monitoring of the UN’s institutional progress on gender equality but also, it seems, ‘gender auditing’ proposals from UN bodies and assisting states in the important work of actually operationalising the UN’s standards.
It is heartening to see reference in the above-quoted aims to the provision by UN Women of “suitable technical and financial support to those countries that request it”, but the wording of this aim does give rise to a number of questions:
► Are states where gender inequality is systemic and where women’s rights standards of the UN are not being implemented really likely to “request” the support of UN women?
► Even if they do, will the agency be sufficiently supported in terms of finance, personnel and logistics to provide adequate “technical and financial support” to help those countries to move towards more effective standards of gender equality?
These are questions that cannot reasonably be answered until we have seen UN Women in operation for some years, but it is difficult to not feel some cautious impulses in considering the likely success of the agency. It is also to be hoped that in deciding how to “to forge effective partnerships with civil society”, UN Women will apply gender equality criteria in selecting its civil society partners, including the effective representation of women within the organisations themselves.
None of these notes of caution are intended to under-play the importance of the establishment of UN Women; this is a genuinely welcome development and one that it is hoped will make real progress in advancing the rights of women and girls, and the cause of gender equality, in and through the United Nations. However, until we see how it operates (and, indeed, is facilitated by the wider UN bureaucracy and the member states) UN Women stands as a symbol of the world’s commitment to gender equality and, without sounding too pessimistic a closing note, more symbolism is the last thing the world’s women need. Action, effective commitment, implementation of CEDAW and genuine progression towards gender equality in all areas of human rights protection—civil, political, social, economic and cultural—are much more urgently required.


(Cross posted from Human Rights in Ireland blog)


Human Trafficking at a Tipping Point

The issue of human trafficking has reached a tipping point. On the same day that I pass by The Body Shop, and see their request that customers sign a petition to stop “sex trafficking of children and young people,” apparently co-sponsored by UNGIFT and UNICEF, a student admits that until I began introducing him to the existence of the issue, he was utterly unaware that people were being bought, sold and exploited around the world.
While many people remain unaware that men, women and children are subjected to indentured servitude, debt peonage and other forms of human trafficking, celebrities and corporations and even conservative American politicians have embraced the issue, at least aspects of it. Angelina Jolie and Microsoft Corporation, through their co-funded and founded organization KIND (Kids in Need of Defense), fund pro bono legal training for unaccompanied children, including children who are trafficked. In her capacity as YouthAIDS Global Ambassador, Ashley Judd has become an advocate against human trafficking. Gloria Steinem and Catharine MacKinnon lend their cultural and legal feminist star power to aspects of the issue. Conservative and moderate politicians such as Olympia Snowe support bills directed towards international violence against women, including human trafficking.
If corporations situated in the Northern Hemisphere; and conservative, moderate and liberal politicians; and celebrities; and law enforcement and all branches of government are lined up in support of aspects of the issue, then why have we failed so miserably to find and then secure assistance to victims of human trafficking and why have we failed to prosecute traffickers? The answer of course is multi-fold, but part of the problem lies in the bifurcation of the issue. The Body Shop wants us to sign a petition to prevent sex trafficking of children. What about the trafficking of Sri Lankan and Nepalese men into Iraq and Afghanistan to provide support services to US troops and their allies? Angelina Jolie and Microsoft will help unaccompanied children. What about agricultural laborers threatened with blacklisting if they complain about non-payment or exploitation? Gloria Steinem and Catharine MacKinnon are concerned with the lack of consent inherent in sex work. What about women who agree to sex work but then have their earnings withheld until they “pay back” their traffickers?
The issue is complex (as IntLawGrrls Janie Chuang and Dina Francesca Haynes have regularly articulated here and here), and the interest of celebrities, politicians and the corporate world is not only laudable, it is often rich and deep. The people who elect to become involved in the issue often become very knowledgeable about it, and yet each selects one aspect in which to become involved, further bifurcating the issue, polarizing the debates and alienating victims who do not fit within their funding or client profile. It is likely the interest in human trafficking will remain for some time. Let us work on making that interest as rich, as meaningful and as holistic as possible.

Dispatch from Oslo

As Beth van Schaack posted earlier today, the University of Oslo is currently hosting The Creation of International Law: An Exploration of Normative Innovation, Contextual Application, and Interpretation in a Time of Flux. This two day conference brings together acclaimed women scholars from around the world to explore challenges relating to the creation and elaboration of international law.
Catharine MacKinnon (left) began the conference with a brilliant keynote address focusing on the trajectory of the crime of rape from its conceptual origin as a crime against an individual into a gender-based crime into an international crime. She gave a brilliant exposition of the reflexive relationship between conceptions of gender in domestic and international law. Organized by Prof. Cecilia Bailliet, an IntLawGrrls guest/alumna, the conference has been a showcase for IntLawGrrl talent.
IntLawGrrls Fiona de Londras, Karima Bennoune and Beth van Schaack presented papers today on varying aspects of international criminal law. On tomorrow's roster are IntLawGrrls Hari M. Osofsky and me, Rebecca Bratspies, both speaking about international environmental law.
The papers from the conference will be published.

The Creation of International Law

Greetings from Oslo, where a number of IntLawGrrls (members, guests, and alumnae) are participating in a conference organized by Cecilia Bailliet and others at the University of Oslo Faculty of Law on The Creation of International Law: An Exploration of Normative Innovation, Contextual Application, and Interpretation in a Time of Flux.

Participants include the following women in international law (IntLawGrrls have a * next to their names):

Henriette Aasen - University of Bergen
Montserrat Abad - Carlos III University of Madrid
Sumudu Atapattu (above left) - University of Wisconsin
► * Karima Bennoune (left) Rutgers School of Law, Newark
► * Rebecca M. Bratspies (right, in black) - CUNY School of Law
Catherine Brölmann (below, in blue) - University of Amsterdam


►* Doris Buss - Carleton University
Rosemary Byrne (right, with scarf) - Trinity College Dublin
Christine Byron - Cardiff Law School (below left, in purple)
►* Hilary Charlesworth (below, in white) - Australian National University

► *Fiona de Londras (below) - University College Dublin
Katherine Del Mar (below right) - University of Geneva
Malgosia Fitzmaurice - Queen Mary University of London School of Law
Anne Hellum - University of Oslo
Agnieszka Jachec-Neale (below right, in front of window) - School of Oriental and Asian Studies
Edda Kristjansdottir - Amsterdam Law School
Catharine MacKinnon - Harvard Law School/U. Michigan Law School
Claudia Martin - AU Washington College of Law
► *Fionnuala Ni Aoláin - U. Minnesota School of Law
Phoebe Okawa (right) - Queen Mary University School of Law
► *Hari M. Osofsky - U. Minnesota School of Law
Inger Johanne Sand - University of Oslo
Kirsten Sandberg (right, in green) - University of Oslo
Birgit Schlütter - Norwegian Center for Human Rights
Hitomi Takemura - NUI Galway & Kyusha International University
► * Beth Van Schaack - Santa Clara University School of Law
► Maria Varaki - PhD candidate, NUI Galway; Irish Centre for Human Rights



Stay tuned for additional postings from the conference.

International Gender Justice Dialogue

From 20-21 April, the Women's Initiatives for Gender Justice in collaboration with the Nobel Women's Initiative hosted the International Gender Justice Dialogue, in Puerto Vallarta, Mexico.
The goal was to bring together gender experts, feminist legal theorists, peace mediators, legal practitioners, jurists, women’s rights advocates, policy makers, members of the media, and activists to identify and develop a strategic, shared agenda for advancing gender justice around the globe.
Although most participants from Europe and Africa were unable to attend because of the volcanic eruption in Iceland (which grounded flights throughout Europe), participants from other regions gathered for a day of panels and a second day of working group discussions. Among the highlights was Women's Initiatives Executive Director and IntlawGrrl guest/alumna Brigid Inder's (pictured right) opening speech, which you can read here.
As Professor Tina Dolgopol (pictured left left), of Flinder Law School in Adelaide, South Australia, noted in her observations about the first day,
A recurrent theme is the necessity of building networks, ensuring that your work
is based on an agreed and transparent set of principles and that you communicate often with your supporters. We hear these ideas from those involved in peace processes, justice networks and from the promotion of women’s rights generally.
IntLawGrrls Kelly Askin and I spoke on a panel entitled "Prosecutions and Jurisprudence - What have we achieved and what remains to be done," along with Professor Catharine A. MacKinnon, who sent in her comments via video. The session was moderated by IntLawGrrl guest/alumna Valerie Oosterveld.
One of the areas I touched on was a project we are undertaking that will hopefully contribute to the process of how we better assess the jurisprudence coming out of the international criminal tribunals, and therefore, the impact these tribunals are having on gender justice.
In October 2008, my office (the War Crimes Research Office at American University's Washington College of Law) organized, in collaboration with the WCL's Women's International Law Program, a two-day conference on “Prosecuting Sexual and Gender-Based Crimes Before International/ized Criminal Courts.” Participants brainstormed about potential strategies and what was needed to improve the prosecution of sexual- and gender-based crimes before these tribunals. High on the list was the need for a modern, searchable, online database of cases (and related documents) coming out of these tribunals, focused on sexual- and gender-based crimes. In response to this need, last year we launched the Gender and ICL Jurisprudence Collections Project. The project has four phases:
1) collection of key decisions, orders and judgments relating to sexual and gender-based violence and making them available online so that you will be able to search them within and across courts;
2) key-wording those cases to facilitate searches relating to how these tribunals have handled cases involving sexual and gender-based violence;
3) digesting those cases with a view to highlighting the facts, allegations or factors affecting the prosecution of such crimes; and
4) providing commentaries on a select number of cases we identify as critical to understanding the development of the law in this area.
The basic aim of the project is to facilitate research in this area by practitioners, advocates and academics, but more importantly to “surface” the decisions that may go unnoticed between indictment and judgment, but which have important consequences for how sexual and gender-based violence is treated by these tribunals.
Follow outcomes from the Gender Justice Dialogue working groups here.

Long way to go in legal academy

Old enough to remember when legal citations eschewed the author's 1st name in favor of 1st initial only?
That style served to obscure the lopsidedness of the legal academy: virtually all the names lurking behind A., B., and C. were men. The mask's largely been lifted, so that each of us today cites in full consciousness of whom we are citing, man or woman. I suspect the change has had good effects, not least among them recognition that women as well as men contribute their voices to this generation of legal scholarship.
Thus even as I celebrated the news that my home institution, the University of California, Davis, School of Law (Martin Luther King, Jr. Hall) is among the Top 25 Law Faculties in Scholarly Impact according to a just-published 2005-2009 survey, I could not but raise a curious eyebrow at the decision of number-cruncher extraordinaire Brian Leiter (prior IntLawGrrls posts here and here) to list the 10 most-cited members of each law faculty by the equation of initial + surname.
A look underneath the veil of that device revealed much:
► In none of the top 25 schools were more than 4 women among the top 10 most-cited scholars, and only 3 of the 25 earned even that scarcely heart-warming 40% rate.
► Double that number -- fully 6 law schools -- do not have a single woman among their top 10 most-cited.
The rest ranged from 1 to 3 women out of 10.
Proud to say that among the women receiving top recognition are 2 IntLawGrrls, Naomi Cahn and yours truly, as well as a number of others whom we've featured in posts: not only my California-Davis colleague Madhavi Sunder, but also Kimberlé Crenshaw, Martha Albertson Fineman, Vicki Jackson, Pamela Karlan, Carrie Menkel-Meadow, Martha Minow (left), Rachel Moran, Catharine MacKinnon (bottom left), Martha Nussbaum, Margaret Jane Radin, and Dinah Shelton.
Proud too to see on the list a close law school classmate, Kirsten H. Engel, as well as the only woman professor I had in law school, Carol M. Rose.
Can't help, though, but be concerned about the dearth of women on this list (reflective, no doubt, of the proportion in the academy as a whole, an issue that my deans, Kevin Johnson and Vik Amar, tackle in this new column on need for faculty diversity).
And can't help harbor concern about the fact that not 1 woman is on Brian's list of Ten Most Cited Faculty 2005-2009; indeed, the list drops a full 660 citations to get to the 1st woman (Kathleen Sullivan) below the 10th man (Bruce Ackerman).
In short, still a very long way to go.


Here's the roundup, with 1st as well as last name provided in full:


Most women among top 10 (4 each):
► Arizona (ranked #21): Jean Braucher, Kirsten H. Engel, Toni Massaro, Carol M. Rose (#10 most-cited woman)
► California-Irvine (#9): Catherine Fisk, Elizabeth Loftus, Carrie Menkel-Meadow, Rachel Moran
► Michigan (#11): Rebecca Eisenberg, Jessica Litman, Catharine MacKinnon (#4 most-cited woman), Margaret Jane Radin (#7 most-cited woman)


Next most -- 3 women among top 10:
► Georgetown (#20): Julie Cohen, Vicki Jackson, Robin West
► Stanford (#4): Pamela Karlan, Deborah Rhode (#3 most-cited woman), Kathleen Sullivan (#1 most-cited woman)
► UCLA (#15): Kimberlé Crenshaw, Katherine Stone, Lynn Stout
► Vanderbilt (#10): Margaret Blair, Nancy King, Suzanna Sherry


Next next-most -- 2 women among top 10:
► California-Davis (#23): Diane Marie Amann, Madhavi Sunder
► Chicago (#3): Lisa Bernstein, Martha Nussbaum (#5 most-cited woman)
► Emory (#23): Martha Albertson Fineman, Barbara Bennett Woodhouse
► George Washington (#18): Naomi Cahn, Dinah Shelton
► Northwestern (#8): Lee Epstein, Dorothy E. Roberts


Only 1 woman among top 10:
► California-Berkeley (#7): Pamela Samuelson
► Columbia (#6): Jane Ginsburg
► Cornell (#11): Valerie Hans
► Harvard (#2): Martha Minow (#2 most-cited woman)
► Illinois (#21): Cynthia Williams
► Penn (#14): Jill Fisch
► Yale (#1): Reva Siegel (#5 most-cited woman)


Not even 1 woman among top 10:
► Duke (#11)
► Florida State (#23)
► Minnesota (#19)
► NYU (#5)
► Texas (#17)
► Virginia (#16)


Perhaps 'nuff said, but thoughts welcome.

Go On! Trafficking in Sex & Labor

(Go On! is an occasional item on symposia and other events of interest) IntLawGrrls will be well represented at the University of Pennsylvania Law Review symposium to be held November 13 and 14 at the Philadelphia-based law school.
"Trafficking in Sex and Labor: Domestic and International Responses" is the title of the conference, which features a keynote address by Catharine MacKinnon, Michigan Law Professor and Special Gender Advisor to the Prosecutor of the International Criminal Court, about whom we've posted. Here're the panels:
Labor Trafficking:
IntLawGrrl Dina Francesca Haynes, New England School of Law; James Gray Pope, Rutgers-Newark; Dr. Joel Quirk, University of Hull, England; Ms. founder Gloria Steinem; and Martina Vandenberg, Jenner & Block. Penn's Tobias Barrington Wolff will moderate.
Trafficking and Immigration Policy:
Jennifer Chacón, University of California, Irvine; Jennifer "J.J." Rosenbaum, Southern Poverty Law Center; and Jayashri Srikantiah, Stanford. Penn's Sarah Paoletti will moderate.
International Responses to Trafficking:
IntLawGrrls Diane Marie Amann (yours truly), University of California, Davis, and Janie Chuang, American University, as well as Norma Ramos, Coalition Against Trafficking of Women. Penn's William Burke-White will moderate.
Sex Trafficking:
Dr. Denise Brennan, Georgetown; Michelle Madden Dempsey, Villanova; Dr. Melissa Farley, of the San Francisco nonprofit Prostitution Research and Education; Illinois attorney Kaethe Morris Hoffer; Ann Jordan, American University; and author/activist Christine Stark. Pamela Shifman, UNICEF, will moderate.
Details and registration here. (photo credit)

Genocide in Cambodia?

The Khmer Rouge seized power on April 17, 1975 (photo, left), marking “year zero” in what turned out to be a four-year campaign to create the “New Cambodia.” Upon the ouster of the American-backed Lon Nol (prior posts here and here), the Khmer Rouge launched a radical project of social reorganization drawing upon communist and Maoist thought to re-construct Cambodia on the backbone of an idealized vision of a rural proletariat. The draconian measures instituted by the regime in this quest included:
► the liquidation of the Lon Nol army and members of the former regime;
► the extermination of the elite and educated;
► a complete evacuation of the urban centers;
► the incineration of books, libraries, banks, places of worship, and university facilities;
► the criminalization of the usage of foreign languages;
► the abolition of money, private property, markets, wages, and salaries;
► the dissolution of families and the separation of children from their parents;
► the subjugation and execution of ethnic minorities;
► the prohibition of religious practice and education; and
► the systematic hunt for real and imagined political opponents.
By the time a Vietnamese invasion opened the killing fields for the world to see in 1979,

a greater proportion of the population [had] perished than in any other revolution during the twentieth century.

Karl D. Jackson, The Khmer Rouge in Context, in Cambodia, 1975-1978: Rendezvous with Death 3, 3 (Karl D. Jackson ed., 1989).
The roughly two million deaths during the Khmer Rouge era are largely considered by the general public -- within Cambodia and abroad -- to be genocide. (The photo at left depicts a map of mass graves). Indeed, Cambodia often bears the dubious distinction of being described as the first post-Holocaust genocide. The U.S. Congress described the Khmer Rouge era as follows:

The persecution of the Cambodian people under the Khmer Rouge rule, [during which time] the bulk of the Khmer people were subjected to life in an Asian Auschwitz, constituted one of the clearest examples of genocide in recent history.

United States Foreign Relations Authorization Act, Fiscal Years 1988 and 1989, Pub. L. No. 100-204, §906. In 1994, Congress passed the Genocide Justice Act, which authorized the creation of a documentation center in Cambodia, later named the Documentation Center of Cambodia (DC-Cam) to develop the United States proposal for the establishment of an international criminal tribunal for the prosecution of those accused of genocide in Cambodia.
The establishment of the Extraordinary Chambers in the Courts of Cambodia (right) to prosecute surviving members of the Khmer Rouge paves the way for the resolution of a lingering question in international criminal law:
► To what extent was genocide committed in Cambodia under the Khmer Rouge?
A quick read of the 1948 Genocide Convention reveals that much of the violence committed by the Khmer Rouge in Cambodia may not constitute genocide, primarily because the perpetrator group and the victim group appeared to share the same nationality, ethnicity, race, and religion. Instead, victims appear to have been targeted on the basis of what an objective assessment would describe as their membership in an undesirable political, social, or economic group. After great debate and compromise, the drafters of the Genocide Convention purposefully denied protection to political, social, economic, and other unenumerated groups. (Today's post below notes tension between the legal meaning of "genocide" and public response to the crisis in Darfur.) As a result, genocide is defined in Article II of the Genocide Convention, which entered into force in 1951, as

any of the following acts committed with intent to destroy, in whole or in part, a national, ethnical [sic], racial or religious group, as such:
(a) Killing members of the group;
(b) Causing serious bodily or mental harm to members of the group;
(c) Deliberately inflicting on the group conditions of life calculated to bring about its physical destruction in whole or in part;
(d) Imposing measures intended to prevent births within the group;
(e) Forcibly transferring children of the group to another group.

Thus, if the ECCC were to be strictly faithful to this original intent, it might reject most charges of genocide that might be brought against the surviving Khmer Rouge leaders. (Charges involving attacks against religious or ethnic minorities in Cambodia would have a better chance of surviving).
Despite this apparently dispositive conclusion, arguments exist for finding genocide in Cambodia based upon modern jurisprudential developments emerging from international criminal tribunals and domestic genocide prosecutions.
First, the original intent of the drafters of the Genocide Convention to exclude protection to unenumerated groups is muted with respect to genocide prosecutions before modern international and hybrid tribunals. This is a function of the origins of these institutions, established treaty interpretation doctrine, and interpretive trends emerging from the various multilateral human rights institutions vis-à-vis their constitutive instruments. Collectively, these factors elevate text and treaty object and purpose as interpretive sources over idiosyncratic intentions of human rights treaty drafters.
Second, contemporary courts engaged in genocide prosecutions have rejected definitions of the protected groups employed at the time of the Convention’s drafting that, by today’s intellectual sensibilities, appear outmoded and even offensive. Instead, modern tribunals have focused on the subjective characterization of these groups within the impacted society at large and -- most importantly -- within the minds of the perpetrators in the dock and the societies that they terrorized. In this regard, international criminal jurists have eschewed identifying an objective or scientific definition of what are inherently contested and contingent concepts. This approach highlights the centrality of the crime’s specific intent element to determining the existence of the crime of genocide.
To be sure, normative arguments can be made about the legitimacy of these jurisprudential trends. Nonetheless, they exist as influential precedent on which the ECCC can draw if it is confronted with the genocide question in the Khmer Rouge context. (To date, no genocide indictments have been issued). In this regard, the ECCC can start from the proposition that the groups listed in the treaty have no independent content; rather, their meaning is inherently contextual, contingent, and historical and should be treated as such. This invites the ECCC to identify the subjective understandings of those terms as they existed within the relevant communities at the time the Khmer Rouge acted, whether or not such conceptions were shared elsewhere or have any objective content or modern resonance. Most importantly, the ECCC must endeavor to understand the intentions of the Khmer Rouge in implementing the radical policies that they did and the identities they ascribed to the individuals they targeted for extermination. As Tufts Law Professor Hurst Hannum has written:
The radical transformation of Cambodia envisaged by the Khmer Rouge required the racial, social, ideological, and political purification of the Cambodian nation, through the sociological and physical liquidation of a variety of groups considered to be irremediably tainted by their association with the old social order or otherwise unsuited to the intended new order.
International Law and Cambodian Genocide: The Sounds of Silence, 11 Hum. Rts. Q. 82, 85 (1989). This “purification” required the extermination or forced assimilation of all non-Khmer ethnic groups, including ethnic Vietnamese, Chinese, Cham, Thai, and indigenous hill communities. It also required the elimination of other individuals whose perceived social, economic, and political affiliations or histories rendered them inherently impure and subject to violent exclusion from the revolutionary program of nation-building. This included Khmer Rouge cadre denounced as spies or counter-revolutionary agents and individuals resident in the Eastern zones hiding “Vietnamese minds in Khmer bodies.”
In implementing this program, the Khmer Rouge were animated by an idealized vision of the “pure Khmer” as both the source and beneficiary of the revolution. This nationalistic vision, however, could not be based on true Khmer ethnicity alone.
► First, the Khmer Rouge considered many indicia of the Khmer tradition and identity to be retrograde, such as the deep attachment to Buddhism. These counter-revolutionary vestiges of a prior identity had to be excised from society.
► Second, many of the key members of the Standing Committee (such as Pol Pot, Nuon Chea, Sao Phim and Khieu Samphon) were of Chinese descent. To accommodate different “objective” ethnicities within the new Cambodian polity, the Khmer Rouge revived the term “Kampuchea,” even officially calling their party the Party of Democratic Kampuchea. The term dates from the 9th century and a romanticized period of the Angkor dynasty, which flourished in South East Asia for 600 years with its capital at the world famous Angkor Wat (below).

In the radical egalitarianism of the Khmer Rouge, all those who were proper Kampucheans were equal; all those who were not were expendable and, indeed, subject to elimination. In this way, the Khmer Rouge invented an ideal type -- with national, ethnic, political, and religious dimensions -- against which all citizens were to be measured. Individuals who did not adhere to these multidimensional criteria were exempt from inclusion, dehumanized, and subject to elimination. (The photo at right is of Cheung Ek, one of the many killing fields around Cambodia).
A finding of genocide writ large in Cambodia is thus feasible through the application of the analysis developed in international and domestic genocide prosecutions. By the subjective approach, it is the Khmer Rouge’s belief system that matters. In the Khmer Rouge’s purification process, individuals from certain political, economic, and social strata were perceived as “imperfect” or “invalid” Khmer, incapable of re-education or assimilation. According to this view, these subsets of society were permanently stained by their prior affiliations and had to be purged lest they hinder the radical societal reformation envisioned by the Khmer Rouge.
An objective assessment of many of these target groups would categorize them as political, social, or economic groups. Viewing these groups through the lens of the Khmer Rouge cosmology, however, these prior social, economic or political affiliations were considered biologically determinative and thus irremediable--the equivalent of a racial, national, or ethnic group. As noted by Michigan Law Professor Catharine A. MacKinnon,

One of the enduring legacies of the Nazis was the notion that culture is genetic.
Rape, Genocide, and Women’s Human Rights, 17 Harv. Women’s L. J. 5, 13 (1994). These individuals were also identified via their exclusion from the majority national group, which fit the ideal type as measured by the Khmer Rouge leadership.
Assuming sufficient evidence exists of this cosmology, the ECCC could reach a finding of genocide writ large within Cambodia.


Why subject legal thought to SurveyMonkey?

Regarding the most-influential-legal-thinker poll that Fiona describes below, the devious among us might wonder whether Brian made his entered-profession-by-1960s cutoff with the devilish purpose of generating feminist buzz.
On reading it last night I myself set to pounce -- to e-mail Brian to find out how Catharine A. Mackinnon (right), to name one unquestionably influential 20th C. legal thinker -- had been omitted. Alas, I learned from WikiPedia that though she's but a few years younger than nominee Bruce Ackerman, she seems not to have earned her J.D. till well after him. No surprise; later entry into one's profession is a hallmark of women's progess.
Even considered within its own time frame, the poll is sadly Anglo-Amero-centric. In a comment to Fiona's post Hannah Arendt (left) was rightly nominated by our colleague Kevin Jon Heller. In global circles the name of my colleague Mireille Delmas-Marty (below) surely would surface. I know others will have other names.
There are so many women and men who've influenced our legal thinking. Do we really need one man's list to tell us who they are?

Special Advisor on Gender Crimes

(In this post, guest blogger Amy Senier returns to the blog with an discussion of the recent appointment of a Special Advisor on Gender Crimes to the International Criminal Court)
A recent appointment by the Prosecutor of the International Criminal Court (ICC) promises a more focused strategy on the prosecution of gender-based violence at the supranational level. Last week, ICC Prosecutor Luis Moreno-Ocampo named Professor Catharine A MacKinnon as his Special Advisor on Gender Crimes. The appointment, announced on November 26, signals an intensified commitment on behalf of the Office of the Prosecutor (OTP) to address gender crimes, an area in which the Prosecutor has drawn mixed reviews for his response to cases and situations in the Democratic Republic of Congo and Central African Republic.
Professor MacKinnon has been at the forefront of feminist international legal thought for nearly 30 years. Her noted works include: Toward a Feminist Theory of the State (1989), Women's Lives, Men's Laws (2005) and Are Women Human?: And Other International Dialogues (2006). She is currently the Elizabeth A. Long Professor of Law at the University of Michigan Law School, where she teaches "Women's Human Rights," "Sexual Equality," and "Men, Women and Conflict." In 2000, Professor MacKinnon served as co-counsel in Kadic v. Karadzic, securing a $745 million damages award for Croat and Muslim rape survivors after successfully arguing that rape constitutes an act of genocide.
Professor MacKinnon's appointment is made pursuant to Article 42(9) of the Rome Statute, which authorizes the Prosecutor to appoint advisors "with legal expertise on specific issues, including, but not limited to, sexual and gender violence and violence against children." Under her new mandate, Professor MacKinnon will work closely with the Prosecutor and Deputy-Prosecutor Fatou Bensouda to "further develop the approach to Gender crimes" within the OTP. Professor MacKinnon is no stranger to the ICC. As recently as October 2008, she briefed the OTP on The Recognition of Rape as an Act of Genocide — Prosecutor v. Akeyesu." The appointment of a renowned scholar and practitioner such as Professor MacKinnon inspires hope of more consistent and proactive prosecutions of gender-based crimes at the ICC.

Forced Marriage: The Facts Don't Fit The Crime

In a recent 631-page decision, Prosecutor v. Alex Tamba Brima et al. (Case No. SCSL-04-16-T) mentioned earlier in this blog, Trial Chamber II of the Special Court for Sierra Leone refused to recognize a discrete offense of forced marriage as either a crime against humanity or a war crime. In so doing, the Court rejected innovative arguments by prosecutors that a crime of forced marriage existed independently of related war crimes and crimes against humanity of rape, sexual slavery, imprisonment, forced labor, and enslavement.
The concept of forced marriage was not a theory originally conceived of by feminist academics or advocates; rather, it came from victims themselves. As the story goes, prosecutors interviewing victims of the brutal civil war in Sierra Leone heard innumerable stories of gang-rape and other forms of sexual violence. Other women, however, described their experience using the vocabulary of marriage. The trial testimony of witness TF1-094 is indicative. TF1-094 was about 12 when her village was raided by rebels. Her parents were killed. She survived, because one Andrew intervened to “save her.” Saving her meant first raping her and then taking her along with him to act as his “wife” (also known by the unfortunate term “bush wife”)—doing laundry and other chores and traveling with his unit as the theatre of war shifted. On cross-examination, she admitted that Andrew generally “care[d] for her.” Andrew was ultimately killed in combat. Other women stayed with their “husbands” post-conflict, often because they knew no other life and had no other life to return to. The rest of the Judgement’s Factual Findings are equally as harrowing.
Through pleading vagaries in the Brima Indictment, the “forced marriage” allegations were adjudicated as the war crime of “outrages upon personal dignity” under Article 3(e) of the Special Court Statute. Exemplifying the normative redundancy of international criminal law, the Prosecutor had also originally charged forced marriage as the residual crime against humanity of “other inhuman acts” under Article 2(i) of the Statute. The Special Court ruled, however, that that provision “must logically be restrictively interpreted as applying only to acts of a non-sexual nature amounting to an affront to human dignity” in light of the “exhaustive category of sexual crimes particularised in Article 2(g) of the Statute,” viz. rape, sexual slavery, enforced prostitution, forced pregnancy and any other form of sexual violence. At the same time, the Court dismissed charges under Article 2(g) as duplicitous, because the Prosecutor did not adhere to the rule of one count, one offense. So, Article 3(e) remained the only “hook” on which the forced marriage allegations could hang. All these machinations in the judgment were after Trial Chamber I had earlier allowed the Prosecution to amend the Indictment to add the forced marriage allegations.
In its Judgement, the Court rejected the notion of forced marriage as a separate and distinct crime. The ruling is arguably based solely on the evidence presented, as the Court determined that the Prosecutor had not established a non-sexual crime of forced marriage that did not wholly overlap with the crime of “sexual slavery” as “[n]ot one of the victims of sexual slavery gave evidence that the mere fact that a rebel had declared her to be his wife had caused her any particular trauma, whether physical or mental.” In other words, the crime of sexual slavery subsumed every case of “bush marriage” presented. The Court went farther, however, in rejecting the very concept when it ruled that even if there had been such evidence, forced marriage would not amount to a crime against humanity because it is not of similar gravity to the other acts set forth in Article 2 of the Statute. The Court left open the question of whether forced marriage could still constitute a war crime, which may not require a heightened showing of harm to all of humanity. All defendants were found guilty under Count 9 for the war crime of outrages upon personal dignity.
Justice Teresa Doherty (left, from Northern Ireland) wrote a compelling dissent. She argued that the phenomenon of forced marriage within the context of the Sierra Leone civil war was distinguishable from the crime of sexual slavery as well as other forms of arguably forced marriage, such as arranged marriages or inheritance marriages, that may implicate human rights norms but not international criminal law.
So often, women’s reality is not acknowledged until it is named. Unlike other international prosecutorial teams—who have been critiqued for failing to elicit, overlooking, ignoring, discrediting, and not pursuing women’s stories of sexual violence in their investigations and indictments—the Special Court’s Prosecutor was clearly listening to women. This Trial Chamber, however, missed an opportunity to acknowledge the lived experience of women and to harness the expressive function of the law. The charge of sexual slavery alone fails to capture the full culpability of the accused and the total experience of the victim who finds herself trapped in a life not of her choosing, saddled with an irreversible conjugal status and innumerable “conjugal duties.” The case lends further credence to the astute observation of Professor Catharine A. MacKinnon (right) that “Women are violated in ways that men are not, or rarely are.” It also provides further evidence of how powerless women may be to control their fates in times of war. One is left to hope that the Prosecution maintains its commitment to the women of Sierra Leone and appeals the Trial Chamber's ruling as a matter of law.

[Posted by IntLawGrrl Beth Van Schaack]
 
Bloggers Team