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164 U. Pa. L. Rev. Online 1 (2015-2016)

handle is hein.journals/pennumbra164 and id is 1 raw text is: ESSAY PROSECUTE, SUE, OR DEPORT? TRANSNATIONAL ACCOUNTABILITY IN INTERNATIONAL LAW CHIMt-NE I. KEITNERt INTRODUCTION On April 8, 2015, the United States deported Salvadoran General Carlos Eugenio Vides Casanova, whom The New York Times described as the highest-ranking foreign official to be deported under laws enacted in 2004 to prevent human rights violators from seeking haven in this country. Thirteen years earlier, a Florida jury found General Vides and a co- defendant liable for $54.6 million in damages for torture and killings by El Salvador National Guard troops under the general's command, the same conduct for which he was ultimately deported.2 On the same day that General Vides was deported, the U.S. Department of Justice filed a request seeking the extradition of Salvadoran Colonel Inocente Orlando Montano Morales, the former Vice Minister of Defense and Public Safety, to face murder charges in Spain for his role in the 1989 Jesuit massacre in El Salvador.' t Harry & Lillian Hastings Research Chair and Professor of Law, University of California Hastings College of the Law. 1 Julia Preston, U.S. Deports Salvadoran General Jbr Role in '8os Killings, N.Y. TIMES, Apr. 9, 2015, at A8. 2 Id. 3 United States Seeks Extradition of Former Salvadoran Military Officer to Spain to Face Charges for Participation in 1989 Jesuit Massacre, U.S. DEP'T OF JUSTICE OFFICE OF PUB. AFFAIRS (Apr. 8, 2015), http://www.justice.gov/opa/pr/united-states-seeks-extradition-former-salvadoran- military-officer-spain-face-charges [http://perma.cc/YAV9-BNR8]. Montano had been sentenced (1)

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