Salvadoran Responses to Invalidation of Its Amnesty Law

As reported in a prior post, the Supreme Court of El Salvador in July 2016 invalidated the country’s 1993 Amnesty Law that had barred criminal prosecution of the most serious violations of human rights during their civil war.

In response the Salvadoran government is preparing legislation to implement that decision and replace that Amnesty Law. In addition, there have been recent important developments regarding three of those violations: (1) the 1980 assassination of Archbishop Oscar Romero; (2) the 1981 El Mozote massacre; and (3) the 1987 assassination of human rights advocate Herbert Anaya Sanabria. All of these developments originally were posted in Tim’s El Salvador Blog and are re-posted or incorporated here with permission.[1]

New Legislation

The Salvadoran government is preparing draft legislation to implement the court ruling and replace the amnesty law. According to an article in Salvador’s El Faro newspaper, the Salvadoran government is seeking advice on such a new law from Juanita Goebertus, an expert Colombian lawyer who participated in the peace accords signed by the Colombian government and the Revolutionary Armed Forces of Colombia (FARC) in 2016. [2]

The key issue is what crimes that were committed during the war are not protected from prosecution and those that are so protected.  The ruling of the court only nullified the amnesty law as it applied to “crimes against humanity.”

Tim’s El Salvador Blog suggests the only crimes against humanity and perhaps war crimes are not exempt from prosecution, but I think that is too narrow. An apparent quotation from the Supreme Court decision in that Blog says the non-exemption applies to “the cases contained in the report of the Truth Commission, as well as those others of equal or greater gravity and transcendence.”

The Rome Statute of the International Criminal Court provides in Article 1 that it shall have “jurisdiction over persons for the most serious crimes of international concern,” which are specified (with definitions) in Articles 6, 7 and 8 as “crimes against humanity,” “war crimes,” and “the crime of genocide.”[3]

According to Tim’s Blog, another issue to be addressed in the new legislation is “whether perpetrators of crimes against humanity will face criminal punishment including jail time.” A Salvadoran newspaper “suggests that both ARENA and the FMLN would like legislation in which the possibility of jail time is eliminated.  What is left unclear is what process will exist to judge responsibility for these crimes and what reparations might be available to victims.    Nor is it clear if the victims have had a voice in defining any of this process.”

Romero Assassination

On March 23–the day before the 37th anniversary of the assassination of Archbishop Romero–“human rights lawyers filed a petition with a court in the capital of San Salvador to reopen the case of this assassination.   They are asking the court to proceed judicially to establish the facts and the responsible parties for this horrible crime.” [4]

El Mozote Massacre

Previous posts have discussed the 1981 massacre  near the Salvadoran village of El Mozote and various legal proceedings regarding this atrocity. [5]

“Twenty ex-members of El Salvador’s military, including high-ranking generals, [this March] have been cited to appear in court in San Francisco Gotera, in Morazan department, in connection with the 1981 El Mozote massacre. On March 29 a Salvadoran court held a hearing to notify nine of these men, including former Defense Minister Jose Guillermo Garcia, ex-chief-of staff Rafael Flores, five other former colonels and two others who did not appear in court that they are being investigated for their alleged roles in the El Mozote massacre. Former Defense Minister Garcia had no comments to the court or the press regarding this development. On March 30 an additional nine former military officials were similarly notified. [6]

This is the first case in a court in El Salvador involving El Mozote and the first case to proceed after last year’s nullification of the 1993 Amnesty Law.”

“The cited officers include  general José Guillermo García, ex-minister of defense; general Rafael Flores Lima, ex-chief of the Joint Chiefs of Staff of the Armed Forces; Colonel Jaime Flores Grijalva, ex-commander of the Third Infantry Brigade; General Juan Rafael Bustillo, ex-commander of the Salvadoran Air Force; and other lower ranking officers involved in the events.”

“The crimes alleged include murders, aggravated rape, kidnapping, acts of terrorism and other offenses.”

“The actions of the judge in San Francisco Gotera responds to a petition by the legal team for the victims headed by Tutela Legal ‘María Julia Hernández.’    The human rights lawyers have complained about the slow, passive approach being taken by the Attorney General’s office which has not moved the case forward despite the removal of the Amnesty Law and a judgment of the Inter-American Court for Human Rights requiring the government of El Salvador to investigate and prosecute these crimes against humanity.”[7]

“The December 1981 El Mozote massacre was perhaps the worst atrocity of El Salvador’s twelve year civil war.  All but one of the civilians taking refuge in the small village of El Mozote, more than 800 men, women, children and babies, were brutally killed by the Salvadoran army.  It is a tragedy the world must never forget.”

Assassination of Human Rights Advocate Herbert Anaya Sanabria

“Salvadoran Attorney General Douglas Meléndez announced that his office is reopening the case involving the 1987 assassination of human rights advocate Herbert Anaya Sanabria.According to an Amnesty International Report in 1988, his killing, carried out by men in plain clothes using silencers on their guns, followed repeated harassment and threats directed at Anaya himself and at other independent human rights monitors in El Salvador.” 

“Although a trial convicted an ERP guerrilla member,Jorge Miranda, for the murder, most believe that the assassination was carried out by government forces. Miranda was released from prison because of the now invalidated Amnesty Law, but the Attorney General said that Miranda would need to be tried again and that if any relative or other interested persons had information about other material actors or intellectual authors of the crime, the prosecutors would pursue any leads.”

Conclusion

We will be paying close attention to Tim’s El Salvador Blog to keep us apprised of further developments on these matters.

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[1] Amnesty or restorative justice?, Tim’s El Salvador Blog (Mar. 28, 2017); Oscar Romero–37 years after his assassination, Tim’s El Salvador Blog (Mar. 24, 2017); Court cites high military commanders in El Mozote massacre case, Tim’s El Salvador Blog (Mar. 15, 2017); Salvador Attorney General opens new war crimes case, Tim’s El Salvador Blog (Mar. 22, 2017); Historic first step towards justice at El Mozote, Tim’s El Salvador Blog (Mar. 31, 2017). Congratulations and appreciation for Tim’s faithful publication of his blog for the last 13 years.

[2] Rauda, Presidencia busca una nueva ley que permita a los criminales de guerra evitar la cárcel, El Faro (Mar. 26, 2017).

[3] The Rome Statute also includes in Article 5(1) (d) “the crime of aggression” as within the jurisdiction of the ICC, but it was not defined until the States Parties did so at the Review Conference of June 2010, and its ratification and applicability is a complex subject that does not need to be addressed here since the crime of aggression seems less relevant to instances of civil war like El Salvador’s.

 

[4] There have been numerous posts about Romero and his assassination. See posts listed in the “Oscar Romero” section of List of Posts to dwkcommentaries–Topical: EL SALVADOR.

[5] See posts listed in the “El Mozote Massacre” section of List of Posts to dwkcommentaries–Topical: EL SALVADOR. A recent article describes the aftermath of the massacre. (Maslin, The Salvadoran Town That Can’t Forget, The Nation (Mar. 30, 2017).)

[6] Ramos, El Mozote sienta en el banquillo al general del Ejército más oscuro, El Faro (Mar. 30, 2017).; Rauda, Pedro Chicas resurrects to prosecute those responsible for El Mozote, El Faro (Apr. 1, 2017)(Google translate).

[7] The decision of the Inter-American Court of Human Rights regarding the El Mozote massacre was discussed in this post: The el Mozote Massacre: Inter-American Court of Human Rights Determines El Salvador Violated the American Convention on Human Rights, dwkcommentaries.com (Dec. 16, 2012).

 

 

U.S. Board of Immigration Appeals Affirms Deportation (Removal) of Former Salvadoran General José Guillermo Garcia

As mentioned in a prior post, in October 2009, the Department of Homeland Security charged that General Jose Guillermo Garcia, who had been residing in the U.S. since his retirement from the Salvadoran military, was removable (or deportable) from the U.S. under the Immigration and Nationality Act on the grounds that he had committed, ordered, incited, or otherwise participated in torture and extrajudicial killings in El Salvador.

The seven-day trial or hearing on these charges before an immigration judge was held in February 2013, and a year later the judge issued his 66-page decision in the case ordering that Garcia should be removed (or deported) from the U.S.This conclusion was based upon the judge’s findings that:

  • “As head of the armed forces and the most powerful person in El Salvador, [García] fostered, and allowed to thrive, an institutional atmosphere in which the Salvadoran Armed Forces preyed upon defenseless civilians under the guise of fighting a war against communist subversives. Instead of institutional changes that would decrease the incidents of killings and torture by the military, [García] failed to stamp out death squads within the security forces.  Likewise, despite contemporaneous evidence that members of the military had been involved in the [1980] assassination of Archbishop Oscar Romero, [1] a man who could have been an ally in bringing about change and peace in El Salvador, [García] failed to adequately investigate.”
  • García helped conceal the involvement of soldiers who killed four American churchwomen in 1980.[2]
  • He “knew or should have known” that army troops had slaughtered the villagers, including women and children, in the hamlet of El Mozote in 1981.[3]

On December 15, 2015, the U.S. Board of Immigration Appeals upheld and finalized the removal order of Garcia in a decision that has not yet been made public. Whether he would exercise his right to appeal to a U.S. court of appeals was not immediately known.

This case has been conducted under the auspices of the Center for Justice and Accountability (CJA), a California-based human rights non-governmental organization. Its Legal Advisor Carolyn Patty Blum applauded the BIA’s decision. She said: “Minister of Defense Jose Guillermo García was the most powerful man in El Salvador during a reign of state terror in which tens of thousands of innocent Salvadorans were slaughtered.  CJA applauds the Department of Homeland Security for its vigorous pursuit of García before the Immigration Court and the Board of Immigration Appeals and thanks our client Dr. Juan Romagoza, once again, for testifying in court proceedings against General García, as he had in the case of former Minister of Defense Eugenio Vides Casanova, deported earlier this year. We hope that García can be swiftly removed from the U.S. and face justice in El Salvador for the El Mozote massacre and the many other crimes committed under his command. It has been a long battle for justice for our clients and other victims who suffered horrendous repression during García’s rule in El Salvador.”

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[1] This blog has published many posts about Oscar Romero.

[2] This blog has published many posts about the American Churchwomen.

[3] This blog has published many posts about El Mozote.

 

 

 

 

 

U.S. Board of Immigration Appeals Decides Former Salvadoran General Should Be Deported

Vides Casanova
Vides Casanova

On March 10, 2015, the U.S. Board of Immigration Appeals (BIA) decided that former Salvadoran General Vides Casanova should be deported from the U.S. [1]

This was the conclusion of the BIA in dismissing Casanova’s appeal from an immigration judge, after trial, deciding that he had had a direct role in the abuse and killings of civilians because of his “command responsibility” as the top military officer of that country. “This is not a case in which isolated or random human rights abuses took place at the hands of rogue subordinates,” the BIA said. General Vides “affirmatively and knowingly shielded subordinates from the consequences of their acts and promoted a culture of tolerance for human rights abuses.”

Specifically in the case of the December 1980 rapes and murders of the four American churchwomen, the Board found that General Vides “knew that National Guardsmen confessed to involvement in the murders, failed to competently investigate the Guardsmen under his command, obstructed the United States’ efforts to investigate, and delayed bringing the perpetrators to justice.” [2]

The BIA decision also reviewed the torture of two Salvadorans, Juan Romagoza Arce and Daniel Alvarado:

  • During 22 days in 1980, Mr. Romagoza was “beaten, shocked with electrical probes all over his body, sexually assaulted with a stick, and hung from the ceiling for several days” and also shot in the arm, his wounds left to fill with worms. Mr. Romagoza reported that General Vides saw him twice during his captivity.
  • Alvarado was tortured for seven days until he falsely confessed to killing a U.S. military adviser, but after an F.B.I. investigation, U.S. officials repeatedly advised General Vides, according to the Board’s decision, that his forces were holding and torturing the wrong man. [3]

As the BIA said, “Congress clearly intended that commanders should be held accountable if their subordinates commit torture and extrajudicial killings.”

General Vides has a right to appeal the BIA’s decision to a U.S. court of appeals so we wait to see if that will happen and the results of any such appeal.

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[1] Matter of Carlos Eugenio Vides Casanova, 26 I&N Dec. 494 (BIA 2015); Preston, General in El Salvador Torture and Killings Can Be Deported, Immigration Court Rules, N.Y. Times (Mar. 11, 2015). Prior posts reviewed the American churchwomen’s work in El Salvador; their 1980 murders; my pilgrimage to the sites of their work and murders; the Salvadoran non-judicial investigations of the crime; the Salvadoran judicial investigation and prosecution of this crime; the Salvadoran Truth Commission’s investigation of the crime; the unsuccessful U.S. civil lawsuit against the generals over the crime under the Torture Victims Protection Act; a 2014 New York Times retro-report of the crime; and the Immigration Judge’s finding, after trial, that Vides should be deported.

[3] A previous post discussed the civil liability of Salvadoran Generals Vides and Garcia for torture of these individuals under the U.S. Torture Victims Protection Act.

New Examination of the 1980 Rapes and Murders of the Four American Churchwomen in El Salvador

The American Churchwomen
The American Churchwomen

 

The November 10, 2014, edition of the New York Times published a video and textual “RetroReport[1] by Clyde Haberman about the December 1980 rapes and murder in El Salvador of the four American Churchwomen: Maryknoll missionaries Maura Clarke, Ita Ford, Dorothy Kazel and Jean Donovan. The article contains disturbing videos of the exhumation of their bodies that month from shallow graves near the airport in that country along with other contemporaneous videos of the churchwomen and U.S. officials and news reports about this horrible crime.

This “RetroReport” was presented as background for the article’s discussion of the pending U.S. legal proceedings to remove or deport two retired Salvadoran generals for having been responsible for those horrible crimes: “José Guillermo García, now 81, and Carlos Eugenio Vides Casanova, 77, [who] have been living in Florida for a quarter-century. They were allowed to settle there during the presidency of George Bush, who, like his predecessor, Ronald Reagan, considered them allies and bulwarks against a Moscow-backed leftist insurgency.”

“But administrations change, and so do government attitudes. Over the past two and a half years, immigration judges in Florida have ruled that the generals bore responsibility for assassinations and massacres, and deserve now to be ‘removed’ — bureaucratese for deported. Both are appealing the decisions, so for now they are going nowhere. Given their ages, their cases may be, for all parties, a race against time.”

The Times pointed out that the proceedings against these two Salvadoran military officers rely on a 2004 U.S. federal statute “prohibiting human rights abusers from entering or living in this country and that [the U.S. government] has broadened its scope to include violators from all over. Immigration and Customs Enforcement, a branch of the Department of Homeland Security, reported last December that over the previous decade, it had obtained deportation orders for more than 640 people.”

This blog has published the following seven posts about the American Churchwomen:

In addition, this blog has published the following four posts about the U.S. proceedings to remove or deport García and Vides Casanova:

Although Garcia and Casanova escaped civil liability for money damages over the murders of the churchwomen in U.S. federal court under the Torture Victims Protection Act, they were held liable for $54.6 million of money damages in another civil case in U.S. federal court involving other victims as discussed in a prior post.

Maura Clarke, Ita Ford, Dorothy Kazel and Jean Donovan continue to inspire many by their living out Jesus’ Gospel of loving God with all your heart, mind and soul and your neighbor as yourself.

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[1] The Times article states that this RetroReport is part of a documentary series that looks back at major stories that shaped the world using fresh interviews, analysis and compelling archival video footage. This nonprofit project, which was started with a grant from Christopher Buck, has a staff of 13 journalists and 10 contributors.

 

Developments in Using U.S. Immigration Law To Enforce International Human Rights

As noted in a prior post, U.S. immigration law provides at least two means of enforcing international human rights.

Removal or Deportation from the U.S. 

Foreigners can be deported or removed from the U.S. if they “ordered, incited, assisted, or otherwise participated in genocide . . . or . . . any act of torture . . . or . . . any extrajudicial killing.” (Intelligence Reform and Terrorism Prevention Act of 2004 sec. 5501, 118 Stat. 3638, 3740 (2004).

Responsibility for enforcing these provisions lies in the Human Rights Violators and War Crimes Unit (HRVWCU) within the National Security Investigations Division (NSID) of the Homeland Security Investigations (HIS) Directorate of the U.S. Immigration and Customs Enforcement (ICE) of the Department of Homeland Security.

This unit conducts investigations focused on foreign human rights violations by individuals in the U.S. in an effort to prevent the U.S. from becoming a safe haven to those individuals who engage in the commission of war crimes, genocide, torture and other forms of serious human rights abuses from conflicts around the globe. Since fiscal year 2004, ICE has arrested more than 250 individuals for human rights-related violations under various criminal and/or immigration statutes. During that same period, ICE has denied more than 117 individuals from obtaining entry visas to the United States and created more than 20,000 subject records, which prevented identified human-rights violators from attempting to enter the United States. In addition, ICE successfully obtained deportation orders to physically remove more than 590 known or suspected human rights violators from the United States.

Currently, ICE is pursuing more than 1,900 leads and removal cases that involve suspected human rights violators from nearly 96 different countries.

Illustrating such cases are two former Salvadoran military officers, Carlos Eugenio Vides Casanova and Jose Guillermo Garcia,[1] and a former Guatemalan military officer, Pedro Pimentel Rios.

In 2012, an immigration judge ruled that Casanova could be deported for his role in multiple acts of killings and torture committed by the Salvadoran military, including the 1980 slayings of the four American churchwomen.

On February 6, 2014, the U.S. Board of Immigration Appeals (BIA) heard Casanova’s appeal from this decision. The main issue was his argument that the removal order was unjustified because the U.S. tacitly had approved the aggressive tactics of the Salvadoran military. In response the ICE attorney argued that U.S. support for the Salvadoran military did not excuse Casanova’s actions and that the U.S. repeatedly had demanded that the Salvadoran military clean up its human rights record. One of the three BIA judges asked whether Casanova was “too far up the chain [of command] to control those units?” The ICE attorney said “no” as Casanova himself testified at his own trial that he kept tight control of the unit. Once the BIA issues its decision, the losing party has the right to appeal to a federal court of appeals.

On February 26, 2014, an immigration judge ordered Garcia to be removed or deported from the U.S. after a trial had determined that he had helped conceal the involvement of soldiers who killed four American churchwomen in 1980 and that he “knew or should have known” that army troops had slaughtered the villagers, including women and children, in the hamlet of El Mozote in 1981. Garcia plans to appeal to the BIA.

In July 2010, ICE charged Guatemalan Pedro Pimentel Rios with being deportable for having assisted or otherwise participated in extrajudicial killings during the Dos Erres massacre in that country. In May 2011 an immigration judge, after trial, determined that he had in fact participated in extrajudicial killings in that massacre and ordered his removal to his home country. That removal occurred in July 2011.

After his return to Guatemala, he was tried by a three-judge court and found guilty of participation in the massacre and sentenced to imprisonment of 6,060 years (30 years for each of the 201 victims). This sentence was largely symbolic since Guatemalan law does not permit prison terms longer than 50 years.

U.S. Conviction and Imprisonment

Foreigners who had gained legal entry or presence in the U.S. can be criminally prosecuted for committing fraud in obtaining a U.S. visa or other immigration benefit (18 U.S.C. § 1546(a)) or committing perjury in statements to U.S. immigration officials (18 U.S.C. § 1621(2)) for failure to disclose their involvement in foreign human rights violations.

Responsibility for enforcing these provisions lies in the U.S. Department of Justice’s Human Rights and Special Prosecutions Section, which “primarily investigates and prosecutes cases against human rights violators and other international criminals . . . for genocide, torture, war crimes, and recruitment or use of child soldiers, and for immigration and naturalization fraud arising out of efforts to hide their involvement in such crimes.”

Examples of such cases are those involving former Salvadoran military officer, Innocente Orlando Montano, and two former Guatemalan military officers, Gilberto Jordan and Jorge Sosa Orantes.

Montano allegedly was involved in various human rights violations in his country, including the November 1989 murder of the six Jesuit priests and their housekeeper and her daughter.[5] Based on his guilty plea, on August 27, 2013, the federal court in Boston, Massachusetts sentenced Inocente Orlando Montano to 21 months in prison for violating U.S. immigration laws.

In 2010, Guatemalan Gilberto Jordan was arrested in Florida for allegedly lying on naturalization forms that allowed him to become a U.S. citizen. He pleaded guilty to failing to disclose on those forms that he had participated in the 1982 killings of at least 162 countrymen in the village of Dos Erres. In September 2010 a federal judge sentenced him to 10 years imprisonment

On October 1, 2013, Jorge Sosa Orantes, a Guatemalan military officer who lead a massacre of a village in his home country, was convicted by a federal jury for making false statements and unlawfully procuring U.S. citizenship when he applied for U.S. residency in 1997 and when he obtained citizenship a decade later. On February 10, 2014, the presiding judge sentenced Sosa with a revocation of his U.S. citizenship and imprisonment for 10 years.

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[1] Garcia and Casanova jointly had been held civilly liable for torture in their country by U.S. federal courts under the Alien Tort Statute (ATS) and the Torture Victims Protection Act (TVPA), but who jointly had escaped similar civil liability under the TVPA for the torture and murder of the four American churchwomen in El Salvador.

U.S. Orders Deportation of Former Salvadoran General

 

General Jose Guillermo Garcia
General Jose Guillermo Garcia

 

As mentioned in a prior post, in October 2009, the Department of Homeland Security charged that General Jose Guillermo Garcia, who had been residing in the U.S. since his retirement from the Salvadoran military, was removable (or deportable) from the U.S. under the Immigration and Nationality Act on the grounds that he had committed, ordered, incited, or otherwise participated in torture and extrajudicial killings in El Salvador.

 

According to that post, on February 27, 2013, an immigration judge in Miami, Florida concluded a seven-day trial or hearing on these charges.

On February 26, 2014, the judge issued his 66-page decision in the case.[1] The judge found that:

  • “As head of the armed forces and the most powerful person in El Salvador, [García] fostered, and allowed to thrive, an institutional atmosphere in which the Salvadoran Armed Forces preyed upon defenseless civilians under the guise of fighting a war against communist subversives. Instead of institutional changes that would decrease the incidents of killings and torture by the military, [García] failed to stamp out death squads within the security forces.  Likewise, despite contemporaneous evidence that members of the military had been involved in the [1980] assassination of Archbishop Oscar Romero,[[2]] a man who could have been an ally in bringing about change and peace in El Salvador, [García] failed to adequately investigate.”

The judge also found that General García helped conceal the involvement of soldiers who killed four American churchwomen in 1980.[3] In addition, he “knew or should have known” that army troops had slaughtered the villagers, including women and children, in the hamlet of El Mozote in 1981.[4]

As a result, the judge ordered that Garcia should be removed (or deported) from the U.S. The lawyer for Mr. Garcia said there will be an appeal.

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[1] This summary of the decision is based upon a New York Times article and a more extensive analysis by the Center for Justice and Accountability. The actual decision is also available on the web.

[2] This blog has many posts about Archbishop Romero.

[3] This blog also has posts about the ministries and murders of the American churchwomen.

[4] The El Mozote massacre also has been a subject in this blog.

The Witness of a Lawyer for Salvadoran Soldier Accused of 1980 Murder of American Churchwomen

In a prior post I described my April 1989 meeting in El Salvador with Salvador Ibarra. He told me and others that a Salvadoran judge had appointed him to represent one of the Salvadoran national guardsmen accused of raping and murdering the four American church women in December 1980.[1]

Someone from the U.S. Embassy, he told us, had asked Ibarra to call a press conference and announce that he had investigated and had found no involvement of higher officials in this horrible crime. This, however, was not true, and he refused to hold a press conference. In response he received death threats that prompted him and his family to flee the country.

I recently came across a May 1985 article that has additional information about his involvement in this notorious case.

The article confirms that Ibarra was appointed by a Salvadoran court to represent one of the national guardsmen accused of this crime, that Ibarra was pressured to not contradict a false statement that the possibility of a cover-up by higher officials had been investigated and found to be baseless and that he received death threats if he did not go along with this strategy.

This pressure, the article reports Ibarra having said, came from other defense lawyers. One was the half-brother of the director of the Salvadoran National Guard while another was a childhood friend of the Salvadoran Minister of Defense at the time, Jose Guillermo Garcia.[2]

When Ibarra told the other lawyers he would not cooperate in this plan, the article states Ibarra said he “was abducted by Salvadoran security forces, held prisoner at national guard headquarters and tortured.” The purpose of his detention and torture, Ibarra said in the article, “was to get him off the case, either by killing him or forcing him to flee the country.”

Sadly Ibarra is deceased, and I cannot ask him questions about this article. But neither account of his involvement in the case directly contradicts the other. Perhaps both are true. There undoubtedly are additional details about this case that probably would emerge in an extended conversation that unfortunately will never happen.

In any event, Ibarra is still a witness and inspiration to me of a courageous lawyer who risked his life to stand up for the truth and zealously to represent his client in a very important case. Moreover, as discussed in the prior post, after having fled to the U.S. because of these pressures, he later returned to his country to be a lawyer for the Lutheran Church’s human rights office, an occupation that again put his life on the line during the Salvadoran Civil War.

Muchas gracias, Salvador Ibarra!


[1] Many prior posts have discussed this horrible crime, its various judicial and non-judicial investigations and my visits to the site of the crime and of the women’s graves in El Salvador.

[2] Other posts have discussed Garcia’s involvement in legal proceedings about this and other crimes in that country.