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33 Fordham Urb. L.J. 637 (2005-2006)
Mother of Atrocities: Pauline Nyiramasuhuko's Role in the Rwandan Genocide

handle is hein.journals/frdurb33 and id is 649 raw text is: MOTHER OF ATROCITIES: PAULINE
NYIRAMASUHUKO'S ROLE IN
THE RWANDAN GENOCIDE
Carrie Sperling*
In the courtroom she prefers plain high-necked dresses that
show off a gleaming gold crucifix she usually wears.' [Hier ap-
pearance in court suggest[s] a school teacher.'2 With her hair pul-
led neatly back, her heavy glasses beside her on the table, she looks
more like someone's dear great aunt than what she is alleged to be:
a high-level organizer of Rwanda's 1994 genocide who authorized
the rape and murder of countless men and women.3
As Pauline Nyiramasuhuko stands trial before the International
Criminal Tribunal for Rwanda (ICTR)4 for crimes against human-
ity and genocide,5 crimes shocking in their depravity, the press
seems more fixated on her gender than the significance of her
crimes and her prosecution.6 The press asks: how could a woman,
a mother, a female that looks so feminine commit such atrocities?7
To ask the question is to assume that women are not capable of
committing acts of violence and depravity such as rape, mass mur-
der, and genocide. In reality, [i]t is probably the case that wo-
men's peacefulness is as mythical as men's violence.8 Women
* Carrie Sperling is an Assistant Professor of Legal Research and Writing at the
University of Oklahoma College of Law. I would like to thank three of the brightest
people I know for their assistance in writing this article-Talitha Ebrite for her excel-
lent research and thoughtful comments, Meg Penrose for her encouragement and su-
perb suggestions, and Vivian Houng for her keen insight and deft editing.
1. Peter Landesman, A Woman's Work, N.Y. TIMES, Sept. 15, 2002 (Magazine),
at 86.
2. Id.
3. Id. at 125.
4. The United Nations Security Council created the International Criminal Tribu-
nal for Rwanda (ICTR) on November 8, 1994. The ICTR is vested with jurisdiction
to prosecute persons responsible for genocide and other violations of international
humanitarian law committed in Rwanda between January 1, 1994 and December 31,
1994. See Statute of the International Criminal Tribunal for Rwanda, Nov. 8, 1994,
available at http://www.ictr.org [hereinafter ICTR Statute]. The Tribunal is located in
Arusha, Tanzania. See Alexandra A. Miller, From the International Criminal Tribunal
for Rwanda to the International Criminal Court: Expanding the Definition of Genocide
to Include Rape, 108 PENN. ST. L. REV. 349, 357-59 (2003).
5. See id. at 366 for a listing of crimes for which Pauline has been prosecuted.
6. See infra notes 155-63 and accompanying text.
7. See infra notes 155-63 and accompanying text.
8. JILL STEANS, GENDER AND INTERNATIONAL RELATIONS 92 (1998).

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