On December 1, 2009, the Second Circuit Court of Appeals upheld a $19 million judgment against Emmanuel “Toto” Constant, the former leader of Haiti’s notorious death squad known as FRAPH, concluding “there is no basis on which to challenge the judgment of the district court,” which awarded $15 million in punitive and $4 million in compensatory damages to three women who survived rape, other torture and attempted killing committed by Haitian paramilitary forces under Constant’s command. The appeal was based on the judgment of the district court finding Constant liable for torture, including rape, attempted extrajudicial killing and crimes against humanity carried out as part of FRAPH’s reign of terror during the period of military rule in Haiti from 1991 to 1994. Today’s ruling is a momentous step for accountability for the state-sponsored campaign of rape that destroyed so many families in Haiti.
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