An Ohio woman, Catherine Zang, filed suit in the U.S. District, Southern District of Ohio after discovering her husband used microphones to record conversations and software to copy her e-mails and instant messages. (Docket No. 1:11CV00884) Catherine and Joseph Zang were in the process of divorcing when Catherine discovered recordings, which she believes went on for months at the least. She surmises that her husband planned to use private communications against her to gain an advantage in divorce proceedings.
The case raises issues of privacy and surveillance in the marital home by a spouse. Chief Judge Dlott must weigh the specific issue of the rights of the husband to set up spy gear in the home against the privacy rights of his wife in the same home. Federal wiretapping laws may also be implicated as internet conversations between Catherine and an out-of-state friend were recorded. (18 U.S.C.A. 2511)
A growing concern in modern society is the development of higher quality and lower cost surveillance equipment. With increased accessibility to cameras, microphones and spyware, it’s believed there is a substantial number of victims of invasions of privacy who remain unaware they’re being target or are ashamed to prosecute perpetrators. Unfortunately, as the wheels of justice turn slowly, the law has yet to catch up to technological advancements.
Perhaps a sense of urgency is what we need to develop next.
For additional materials on this issue, the following advanced queries may be run on WestlawNext:
TI(inva! /2 privacy & technolog!) (2) Content: Secondary Sources Jurisdiction: All State & FederalCASES adv: DI,SY(eavesdrop! (inva! right /3 privacy) spy) and TO(divorce) (113) Content: Family Law Cases Jurisdiction: All State & Federal The topic KeyNumber for invasion of privacy is 379IV.
inva! /2 privacy /p advanc! /5 technolog! (52) Content: Cases Jurisdiction: All State & Federal
spy! eavesdrop! /p husband wife spouse /s home residence house /200 right /2 privacy (6) Content: Overview Jurisdiction: All State & Federal
On July 30, the US Supreme Court granted a stay of judgment to the state of Maryland in the case of Maryland v. King (2012 WL 3064878, Petition for Writ for Certiorari found at 2012 WL 3527847). At issue is whether the warrantless collection of DNA samples prior to conviction pursuant to the Maryland DNA Collection Act (MD PUBLIC SAFETY § 2-501, et. seq.) is constitutional under the Fourth Amendment.
The Maryland DNA Collection Act (pre-conviction DNA collection is effective until January 1, 2014) authorizes the collection of DNA samples from individuals charged with “a crime of violence” or burglary or attempted burglary. (MD PUBLIC SAFETY 2-504(3)).
In 2009, King was arrested on assault charges and his DNA was collected, analyzed and entered into Maryland’s DNA database pursuant to the Act. Pending his trial on that charge (for which he was ultimately convicted), his DNA was matched to a sample collected during the investigation of a 2003 unsolved rape. The match provided the sole probable cause for a grand jury indictment. He was convicted of first-degree rape and sentenced to life in prison.
In a fairly narrow ruling, the Maryland Court of Appeals held that King’s privacy interests outweighed the state’s interest in assuring proper identification of him as to the crimes for which he was charged at the time. However, the Court noted that it could foresee a different conclusion based on different facts:
Although we have some trepidation as to the facial constitutionality of the DNA Act, as to arrestees generally, we cannot exclude the possibility that there may be, in some circumstances, a need for the State to obtain a DNA sample to identify an arrestee accurately.
King v. State, 42 A3d 549 at 553.
If the US Supreme Court grants certiorari for this case, how is it likely to rule? I ran the following search in U.S. Supreme Court Cases on WestlawNext (SCT on Westlaw Classic):
di(“fourth amendment” privacy /s arrest!)
I then sorted by “most cited” and produced several landmark Fourth Amendment cases within the first 20 hits, including Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868 and Schmerber v. California, 384 U.S. 757, 86 S.Ct. 1826.
In a second search, I tried the following in the same content:
privacy “fourth amendment” /p d.n.a. blood finger-print urine breath (bod! /3 fluid)
Again I sorted by “most cited” and again produced Schmerber, along with Skinner v. Railway Labor Executives’ Ass’n., 489 U.S. 602, 109 S.Ct. 140 and Davis v. Mississippi, 394 U.S. 721, 89 S.Ct. 1394. These would all likely be central to the Court’s analysis of privacy rights versus public safety.
But Davis, which addresses the collection of fingerprints during detention, may provide particularly valuable insight into the Court’s balancing of pre-conviction DNA collection and the Fourth Amendment:
Fingerprinting involves none of the probing into an individual’s private life and thoughts that marks an interrogation or search. Nor can fingerprint detention be employed repeatedly to harass any individual, since the police need only one set of each person’s prints. Furthermore, fingerprinting is an inherently more reliable and effective crime-solving tool than eyewitness identifications or confessions and is not subject to such abuses as the improper line-up and the ‘third degree..’
Davis v. Mississippi, 394 U.S. 721, 727 (1969).
Last April, Marcus Raymond Robinson , a former death row inmate in North Carolina, became the first beneficiary of that state’s Racial Justice Act, when his sentence was commuted to a sentence of life imprisonment without the possibility of parole. See 2012 WLNR 8439889.
This hearing heightened calls for a repeal of the Racial Justice Act (more accurately, to reform the act in a way that make it more difficult to invoke). The North Carolina Legislature actually already voted through the changes, but Governor Perdue vetoed it.
North Carolina passed the Racial Justice Act, N.C.G.S.A. s 15A-2010 et seq., in 2009. The act, broadly, allows North Carolinians to challenge their death sentences on the grounds that it was handed down as a result of racial discrimination, including discrimination in the exercise of peremptory challenges. Crucially, North Carolina doesn’t bar the use of statistical evidence to prove peremptory challenge discrimination; if a convict can show that members of a race were preferentially chosen for juries, or were preferentially excluded, that can be enough to have a capital sentence judicially commuted to life without parole. In fact, that’s exactly how Mr. Robinson did it.
Mr. Robinson should feel lucky challenged his sentence when he did. After failing to override the Governor’s veto in January, the legislature found enough votes for an override on July 2. See 2012 WLNR 13966766.
N.C.G.S.A. s 15a-2011 discusses the use of statistical evidence to challenge jury composition. For comparison see Kentucky’s version of the act, at KRS s 532.300, which doesn’t address jury composition as a factor to be raised in a fairness hearing.
To see the progress of the N.C. Legislature’s repeal, try the following search in NC-Billtrk: SU,TE(RACIAL /3 JUSTICE). For the actual legislation try racial /3 justice in nc-bills, though, given the override, you can run the search in NC-Legis as well.
To find material on Marcus Robinson’s commutation, I ran the following search in ALLNEWS: racial /3 justice /3 act & north /2 carolina & judge /3 weeks
Mr. Robinson was not the only man on death row to challenge his sentence. To see challenges filed by other prisoners, and to get a sense of the evidence that has been marshaled to show discrimination in North Carolina, try this simple Plain Language search in North Carolina State Trial filings: racial justice act
The repeal is effective immediately, which has led to the question of what version applies to challenges that were filed but not yet decided when it went through. That litigation hasn’t yet made its way into actual opinions, but you can run the following plain language search in North Carolina news: Racial justice repeal pending cases. Limiting the results to those since July 2 gives a sense of what the inmates are trying to get the older version of the law applied.
“My first offense, and they gave me all this time. Might just as well say I’m dead.”
Those are the solemn words of Quartavious Davis who, in 2010, was an 18-year-old accused of carrying and twice discharging a firearm during a series of robberies in the Miami area. 2012 WLNR 13925081. On the basis of his accomplices’ testimony, he was convicted in federal court and sentenced to nearly 162 years in prison without the possibility of parole. His accomplices received plea deals in exchange for their testimony and received sentences ranging from nine to 22 years in prison. Quartavious Davis’ conviction raises the question of just what is “cruel and unusual punishment.” (U.S.C.A. Const. Amend. VIII)
The U.S. Supreme Court has held that a life-without-parole sentence is “grossly disproportionate” when imposed on one under 18 years of age. Graham v. Florida, 130 S. Ct. 2011, 2043. Consequently, such a sentence violates the 8th Amendment clause proscribing cruel and unusual punishment. This provides little solace for Davis, who was 18 at the time of the crimes. However, it is fair to suggest that a prison sentence exceeding a century for an 18-year-old first-time offender also qualifies as grossly disproportionate. This argument will likely be made by Davis’ attorney, who has appealed to the Eleventh Circuit Court of Appeals.
The 162-year sentence imposed on Davis results from “stacking”—considering each count in an indictment as a separate crime, subjecting a defendant to multiple sentences and mandatory sentencing guidelines. Davis was convicted of seven counts of possession of a firearm in furtherance of violence. 18 U.S.C.A. 924(c)(1)(A). He received seven years for the first firearms count and 25 years for each subsequent count. The controversial practice of stacking is supported by those who argue it protects the public by incapacitating criminals for longer periods of time through incarceration, but rejected by opponents who believe it results in excessive and unjust sentences.
There’s no disputing where Quartavious Davis stands on the issue:
“There ain’t no justice in the justice system.”
2012 WLNR 13925081
For additional materials on this issue, the following queries may be run on WestlawNext:
stacking concurrent! /s sentenc! /s mandatory /s federal /s crim! (31) Content: Secondary Sources Jurisdiction: All State & Federal
stacking concurrent! /s sentenc! /s mandatory /s federal /s crim! (6) Content: Cases Jurisdiction: All Federal
On Friday, June 22nd, a jury found Jerry Sandusky guilty of sexually abusing ten boys. He was charged with 45 counts of sexual abuse, to be served consecutively. This means that at 68, Mr. Sandusky will most likely spend the rest of his life in jail. Sandusky Guilty Of Sexual Abuse Of 10 Young Boys, 2012 WLNR 13114287
Although most of the documents are sealed, the docket from the Supreme Court of Pennsylvania denying extraordinary relief is available on Westlaw and WestlawNext in the Pennsylvania state court dockets at 102 MM 2012. Some of the filings and briefs from the case can also be found by searching ti(Gerald /3 sandusky) in the Pennsylvania state and federal materials on WestlawNext.
The assistant coach at one of the most well-known institutions in college football, Penn State, was revered by many for his feats in leading his team time and again to victory on the playing field. In addition to the time he spent as a coach, Mr. Sandusky also created a charity for wayward boys which he called “Second Mile.” It is through this charity it is said he found many of his victims. At Trial, Sandusky’s Wife Comes to His Defense, 2012 WLNR 12809390
The prosecution’s case against Mr. Sandusky was quite damning, to say the least. In addition to the grueling testimony from the victims and other witnesses, the prosecution also offered into evidence a series of letters from Mr. Sandusky to his young charges which have been described as being rather romantic in nature. The defense provided the interesting alternative of “histrionic personality disorder” as a reason for the effusive letters. Although this condition might have caused Sandusky to seek attention with the letters, the defense experts argued, histrionic personality disorder would not necessarily lead him to molest children. Sandusky defense may use psychiatrist, 2012 WLNR 12854159
In Attorneys Medical Advisor, histrionic personality disorder is defined as “dramatic, flamboyant, extroverted behavior in patients with widely fluctuating emotions.” 6 Attorneys Medical Advisor § 46:15
Obviously, this defense did not work out for Mr. Sandusky. In fact, many in the press wondered about the soundness of offering it as an option in the first place. Invoking Scarlett O’Hara? ** Sandusky lawyers say histrionic personality disorder explains ‘love letters’ to accusers., 2012 WLNR 12775150
But as it turns out, this disorder has come up as a defense before in several other cases. Try the following search in ALLCASES in Westlaw or All State and Federal Materials in WestlawNext to get a sense of how histrionic personality disorder has been used in previous cases:
Histrionic /3 personality behavior /p defense
In secondary sources, this search reveals that histrionic personality disorder has been used to terminate parental rights, to discredit female victims of sexual assault, as a reason to grant lesser sentences under Federal Sentencing Guideline 5K2.13 in nonviolent cases, and as a cause for eligibility under the federal social security act.
Some interesting cases where histrionic personality disorder was offered as a defense include:
State v. Burris, 298 N.J. Super. 505, 689 A.2d 860 (App. Div. 1997): a young lady who claimed to have killed her mother by accident proffered histrionic personality disorder as a reason for her calm and collected manner after her mother’s death. She was charged with murder at the trial, but the case was reversed on appeal because the court held that her right to remain silent was violated when the trial court refused to allow expert testimony regarding her mental condition unless she testified. The defense didn’t work at the new trial—she was again charged and sentenced to 30 years in prison with eligibility for parole after 12 years.
People v. Mercer, 70 Cal. App. 4th 463, 82 Cal. Rptr. 2d 723 (1999): Defendant was determined to be a sexually violent predator who would reoffend if he was released. On appeal, the court asked to review whether all of the elements for finding someone to be a sexually violent predator had been met. One of the elements required the finding that the party had a diagnosable mental disorder. While the prosecution’s experts determined that the defendant had a personality disorder with schizoid features, the defense expert testified that the defendant had histrionic and narcissistic tendencies. The prosecution experts reached the conclusion that the defendant would repeat his sexually deviant behavior and the defense stated that there was no evidence that the defendant would likely reoffend. The court affirmed the lower court’s judgment.
As these two cases show, histrionic personality disorder may not be very successful as a defense, but it hasn’t stopped people from trying.
Tess Wilkinson-Ryan, Admitting Mental Health Evidence to Impeach the Credibility of A Sexual Assault Complainant, 153 U. Pa. L. Rev. 1373 (2005)
Parents’ Mental Illness or Mental Deficiency As Ground for Termination of Parental Rights-General Considerations, 113 A.L.R.5th 349 (Originally published in 2003)
What constitutes “disability” within Federal Social Security Act, 77 A.L.R.2d 641 (Originally published in 1961)
Downward departure under § 5K2.13 of United States Sentencing Guidelines (U.S.S.G.) permitting downward departure for defendants with significantly reduced mental capacity convicted of nonviolent offenses, 128 A.L.R. Fed. 593 (Originally published in 1995)
Generalized Anxiety Disorders, 27 Am. Jur. Proof of Facts 3d 1 (Originally published in 1994)
On May 8th the New York Court of Appeals ruled that it is not illegal to view child pornography online. In a case involving defendant James Kent, a former Marist College professor, the court found that some images in Kent’s computer cache, could not legally be held against him. The rationale behind the finding is that there must be an affirmative act demonstrating a defendant exercised dominion and control over the images on a computer screen. Absent such an affirmative act there is merely viewing and not possession or procurement. — N.E.2d —-, 2012 WL 1580439
A State Senator and an Assemblyman have announced they’ll introduce legislation making it illegal to “knowingly access” child pornography. There is precedent for such legislation, specifically in Alaska. AS § 11.61.127 states, in part:
A person commits the crime of possession of child pornography if the person knowingly possesses or knowingly accesses on a computer with intent to view any material that visually depicts conduct described in AS 11.41.455(a) knowing that the production of the material involved the use of a child under 18 years of age who engaged in the conduct or a depiction of a part of an actual child under 18 years of age who, by manipulation, creation, or modification, appears to be engaged in the conduct.
Though morality cannot be legislated, it is comforting to know Alaska, New York and others are endeavoring to identify and prosecute those who intend to exploit the most vulnerable of citizens: our children.
For additional information on this topic:
Search – (procure access view possess) child pornography Content – All States
On Westlaw or WestlawNext:
Search – possess! procur! /s porn! /5 child Content - New York (People v. Kent should be the first result on WestlawNext)
Search – ti(POSSESS! PROCUR! /S PORN! /5 CHILD) Content – Secondary Sources
Search – PR,CA,TE(KNOW! /5 POSSESS! PROCUR! ACCESS! /S PORN! /5 CHILD) Content – Statutes and Court Rules, or Pending and Enacted Legislation
Last month, the Wisconsin Supreme Court accepted for review State v. Neumann, 2012 WL 1500112. This case involves the application of a statutory exception to child abuse prosecution where a parent relies on “spiritual treatment” or “faith healing,” and whether the parent can then be subject to prosecution for reckless homicide where the child dies due to lack of medical treatment.
The Neumanns were the parents of an 11-year-old girl who died of a diabetes-related condition. At the time their daughter became sick, the Neumanns were not aware that their daughter had diabetes. Once the girl started exhibiting symptoms of illness, her condition declined rapidly over the course of 48 hours. Instead of seeking immediate medical intervention, the Neumanns relied on prayer to heal their daughter. By the time that conventional medical treatment was sought, it was too late. With more timely medical treatment, experts testified, the child would almost certainly have recovered.
The Neumanns are not the first parents to face prosecution for failure to secure medical treatment for a child. A search on WestlawNext for “faith healing” of child turns up numerous cases with similarly tragic facts. As in the Wisconsin case, others involve state statutory exceptions to criminal prosecution for a parent’s choice to rely on spiritual treatment. In many of these cases, the issue before the court often does not turn on the Constitutional guarantee of religious freedom, but rather on the construction of the statutes at issue.
An Ohio court held in State v. Miskimens, 490 N.E.2d 931 (1984), that the state statute governing prosecution for child endangerment was made unconstitutionally vague by its spiritual treatment exception. The prosecution against the parents was therefore dismissed.
On the flip side, the California case Walker v. Superior Court, 47 Cal.3d 112 (1992), held parents could be prosecuted for involuntary manslaughter and felony child endangerment over the death of their child. Although the misdemeanor child endangerment statute provided an exception for treatment by prayer, the parents could be prosecuted under the existing felony statutes without infringing on Due Process for failure to provide notice of illegal conduct.
For further discussion, take a look at the Secondary Sources on WestlawNext, again searching “faith healing” of child. A number of law review articles have tackled this difficult issue over the years. You might also start with an in-depth review by checking out ALR’s, Parents’ Criminal Liability for Failure to Provide Medical Attention to Their Children, 118 A.L.R.5th 253.
Earlier this month New York Governor Andrew Cuomo proposed legislation reducing the penalties for possession of small amounts of marijuana from a criminal misdemeanor to a violation, (See 2011 NY A.B. 10581 (NS)) arguing the need to reduce the chance that a person will be burdened with a criminal record after being found with only small amounts of marijuana during a police stop-and-frisk. The relevant New York statute, McKinney’s Penal Law § 221.10, criminally penalizes “public view” possession while private possession is only a “violation”, McKinney’s Penal Law § 221.05.
The bill mirrors a New York City police directive issued last year for officers to issue violations, not misdemeanors, for “small amounts of marijuana that come into open view during a search.” See 2012 WLNR 11751302. Said Cuomo:
It’s incongruous. It’s inconsistent the way it’s been enforced. There have been additional complications in relation to the stop-and-frisk policy where there are claims young people could have a small amount of marijuana in their pocket, where they’re stopped and frisked. The police officer says, —Turn out your pockets.’ The marijuana is now in public view. It just went from a violation to a crime.’
Other states have similar legislation pending. To find current bills and session laws regarding marijuana penalties, try the following search in Proposed & Enacted Legislation on WestlawNext after choosing “All States” for your jurisdiction (or ST-BILLTXT and LEGIS-ALL on Westlaw Classic):
marijuana possession misdemeanor violation infraction
For an overview of marijuana possession statutes currently in effect, the 50 State Surveys is a great resource. On WestlawNext, select “Statutes and Court Rules”, then “50 State Surveys” under “Tools and Resources.” Enter “marijuana” in the search box. Select “Illegal Drugs: Marijuana”, 0030 SURVEYS 3 (the search also produces surveys for cocaine, methamphetamine and heroin, which may also be of interest).
Also, for a recent discussion of how tightened state budgets are leading to the decriminalization of small amounts of marijuana, See THE WAR ON DRUGS, THE POLITICS OF CRIME, AND MASS INCARCERATION IN THE UNITED STATES, 15 J. Gender Race & Just. 315. See also, RACE, DRUGS, AND LAW ENFORCEMENT IN THE UNITED STATES, 20 Stan. L. & Pol’y Rev. 257. To produce these articles, and others regarding drug laws, enforcement and disparate incarceration rates, run the following search in Secondary Sources on WestlawNext (TP-ALL on Westlaw Classic):
ti(drug marijuana marihuana /5 law regulat! crim! /10 “united states” u.s.)
In the run-up to his impending jury trial, the judge in the case of Commonwealth v. Gerald Sandusky has ruled that Jerry Sandusky’s accusers cannot testify under pseudonyms at the trial.
The judge in Jerry Sandusky’s child sexual abuse case says the alleged victims can’t avoid disclosure of their names by testifying under pseudonyms. He also is banning tweets and other electronic communications from inside the courtroom.
6/4/12 AP Alert – PA 13:42:33
“Secrecy is thought to be inconsistent with the openness required to assure the public that the law is being administered fairly and applied faithfully,” Cleland wrote in his order dismissing the request. “It is argued in the motions that for an alleged victim of a sexual assault to fulfill that responsibility is so uniquely embarrassing that the person should be protected by being able to conceal his name. But why should any class of witnesses be protected? No victim of crime, after all, is spared the trauma of crime’s effects – and the severity of the trauma does not necessarily mirror the nature of the crime,” the judge said. Cleland called the motions for pseudonyms “complicated, even controversial.”6/4/12 Reuters News 16:28:36 The judge called the decision “controversial,” but this doens’t appear to be the case in all jurisdictions. A quick WestlawNext search in All State and Federal brings back some interesting results: Search: victim testify using pseudonym Notably, in the first few results under statutes it is clear that both Texas and Nevada provide statutory mechanisms for just the type of result the accusers’ attorneys were seeking in the Sandusky case.
A victim of a sexual offense or an offense involving a pupil may choose a pseudonym to be used instead of the victim’s name on all files, records and documents pertaining to the sexual offense or offense involving a pupil, including, without limitation, criminal intelligence and investigative reports, court records and media releases.Nev. Rev. Stat. Ann. § 200.3772 (West)
A victim may choose a pseudonym to be used instead of the victim’s name to designate the victim in all public files and records concerning the offense, including police summary reports, press releases, and records of judicial proceedings. A victim who elects to use a pseudonym as provided by this article must complete a pseudonym form developed under this article and return the form to the law enforcement agency investigating the offense.TX CRIM PRO Art. 57.02(b) While a few states do have provisions for this type of protection for accusers in criminal cases, it seems far more common in the civil realm, as a great majority of the cases and secondary sources that come up in the results for that search deal with protecting a victim’s identity during the pendency of a civil suit. Perhaps the notorieity and publicity surrounding the Sandusky trial will cause some states to revisit those policies.
The KONY 2012 video now has nearly 84 million views. The video, produced by the non-profit, Invisible Children , feature’s Joseph Kony, a leader of The Lord’s Resistance Army in Uganda. He is currently wanted for war crimes. The video has been the subject of some recent criticism:
Well, the biggest issue that I’ve raised or perhaps the easiest to understand to begin with is that the Lord’s Resistance Army, led by Joseph Kony, was actually forced out of Uganda by the Ugandan military in 2006. So I came to start paying attention to this “Kony 2012″ campaign because all of a sudden on all of the places that I monitor – things happening in Uganda – there were these hordes of people saying stop the war in northern Uganda. Let’s go to northern Uganda and get rid of Kony. And there is no war in northern Uganda anymore, not since 2006. The LRA is still what I like to call a regional wrecking ball. It’s still raiding and massacring and abducting in neighboring countries, but northern Uganda itself is peaceful.
For background on Kony, try
Query: TI(“JOSEPH KONY” “LORD RESISTANCE ARMY”) (WORLD-JLR)
This search yields 9 RESULTS. Notably, it looks like most of these are articles are a touch dated, (2002-2006). However, the Harvard Human Rights Journal had a great historical background of the Army and Kony. The article gave a brief background of Joseph Kony:
“The LRA has been active since the late 1980s, when Joseph Kony, a self-proclaimed messianic prophet, began his mission to free the Acholi people of northern Uganda by overthrowing the government and installing a system based on the Biblical Ten Commandments. The LRA was the last of a string of rebel movements that arose after Museveni seized power in 1986.
H. Abigail Moy, The International Criminal Court’s Arrest Warrants and Uganda’s Lord’s Resistance Army: Renewing the Debate over Amnesty and Complementarity, 19 Harv. Hum. Rts. J. 267 (2006) at 267.
The article also pointed out what crimes the ICC (International Criminal Court) accused Kony of. It states:
“In accordance with the limits on the ICC’s jurisdiction, the Court’s arrest warrants focus on events from 2002 onwards. The ICC alleges that LRA leader Joseph Kony issued specific orders in mid-2002 and late 2003 to attack, kill, loot, and abduct civilian populations, including those living in IDP camps. Luis Moreno Ocampo, the ICC Prosecutor, has submitted evidence supporting the allegation that the LRA commanders named in the warrants directly participated in carrying out these orders. Of the five people identified for arrest, Joseph Kony has the most counts against him: twelve counts of crimes against humanity including murder, enslavement, sexual enslavement, rape, and inhumane acts of inflicting serious bodily injury and suffering, as well as twenty-one counts of war crimes, including cruel treatment of civilians, intentionally directing an attack against a civilian population, pillaging, rape, and the forced enlisting of children.” Id at 268-269.
For more recent information without the You-Tube references, try the following searches:
Query: da(aft 2006) & atleast4(kony) & l.r.a. “lord resistance army”
Database: allnews, rallnewsplus, or blogsod
Query: da(aft 2006) & JOSEPH /2 KONY & L.R.A. “LORD RESISTANCE ARMY” % FACEBOOK YOU-TUBE SOCIAL-MEDIA
The ICC website can be searched as well: