DOE V. CONSTANT

“I saw death in front of me,” Jane Doe 1 testified from behind a large black screen in a federal courtroom in New York City. Her husband was a democracy activist in Haiti who supported the return of President Jean-Bertrand Aristide. Aristide had been deposed by a military coup in 1991. Jane Doe 1's husband disappeared along with scores of other Aristide supporters during that nation's military dictatorship. She remembered that, on January 27, 1992, her husband “went to work to drive his taxi” and that day the military “massacred 14 people.” “He was the 15th,” she surmised. After her husband's disappearance, Jane Doe 1 publicly demanded information about his whereabouts and she demanded justice. “I couldn't remain silent,” she testified, “I was crying and yelling for justice.” After only a few weeks, five or six men, armed and masked, entered her home, where she lived with her three young children. She recalled the men told her to “stop talking about my husband” and that they said “they would make me stop talking.” The men beat Jane Doe 1 and detained her in a local penitentiary for five days. She recounted, “They stripped me of my clothes [and] beat me everyday.” Then “they released me in the middle of the night all naked.”