I am a leader of FRAPH, Emmanuel Constant, Haiti

Toto Constant

I am a leader of FRAPH, Emmanuel Constant, Haiti


Human Rights Developments

Human rights violations in Haiti mounted in 1994 as the military regime increasingly turned to terror
tactics in its effort to eliminate all vestiges of support for elected President Jean-Bertrand Aristide.
During the first half of the year, as international efforts to restore democracy foundered, the army
joined forces with paramilitary thugs in a marathon of gross human rights violations.

In May, the Clinton administration stepped up pressure on the regime through stiffer international
sanctions and threatening the use of force. In September, a last-minute agreement with the regime
led to the unopposed occupation of Haiti by a U.S.-led multinational force. Within weeks, the coup
leaders had stepped down and President Aristide returned on October 15. The U.S. deployment
interrupted the regime's campaign of brutality, although violent incidents continued to occur.

Violations previously less common in Haiti emerged as patterns during the first months of the year.
These included forced disappearances, rapes, and grotesque murders, crimes calculated to terrorize
the population at large. These acts were increasingly directed against the relatives and neighbors of

The army used armed civilian adjuncts, or attachés, to crush civil society. The army-backed
paramilitary group calling itself the Front for the Advancement and Progress of Haiti (FRAPH)
continued to be implicated in countless human rights crimes. Composed of well-armed
neo-Duvalierists and attachés, FRAPH opened offices around the country and established informer
networks in numerous communities, recruiting members through bribery and terror.


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I am a leader of FRAPH, Emmanuel Constant, Haiti


1 Deposition of Emmanuel Constant, Alerte Belance v. FRAPH, No. 94-2619 (E.D.N.Y. filed June 7, 1995).

2 Human Rights Watch, World Report–Haiti (1995).

3 Human Rights Watch, Terror Prevails in Haiti (April 1994).

4 Declaration of Robert E. Maguire, May 18, 2007.

5 Findings of Fact and Conclusions of Law, Doe v. Constant, No. 1:04-cv-10108-SHS (S.D.N.Y. Oct. 24, 2006).

6 Declaration of Mario Joseph, May 2007.

7 Judgment, Raboteau Trial, Tribunal of First Instance of Gonaïves (Haiti), Nov. 16, 2000.

8 David Grann, “Giving ‘The Devil’ His Due”, The Atlantic, June 2001.

9 Declaration of Brian E. Concannon, Jr., Esq., May 18, 2007.

10 US Dep’t of State, Country Report on Human Rights Practices in Haiti, 2014.

11 Joseph Guyler Delva, “Protestors vow to derail Haiti presidential vote; election offices burned,” Reuters, Jan. 18, 2016.

12 Letter of Warren Christopher to Att’y Gen. Janet Reno, March 29, 1995.

13 Declaration of Scott A. Gilmore, Esq., Jan. 22, 2016.

14 Hearing Transcript, Doe v. Constant, No. 1:04-cv-10108-SHS, (S.D.N.Y. Aug. 29, 2006).

15 Haitian-American Women’s Advocacy Network, et al., Organization of American States, Inter-American Commission on Human Rights, Communication Respecting the Violations of Human Rights of Haitian Women, (October 1994).

16 OAS-IACHR Communication, Affidavit of Victim 3 (1994).

17 OAS-IACHR Communication, Affidavit of Victim 4 (1994).

18 Organization of American States, Inter-American Commission on Human Rights, Report on the Human Rights Situation in Haiti (1995) (excerpt).