|n59. See Yeoman, supra note 4, at 43 (noting that "since the late 1990s, the United States has paid private military companies an estimated $ 1.2 billion ... to eradicate coca crops and to help the Colombian army put down rebels who use the drug trade to finance their insurgency"); see also Kurlantzick, supra note 20; Pape & Meyer, supra note 2; Tepperman, supra note 13, at 10; Wayne, supra note 2.
n60. Singer, supra note 20, at 206-08; Guillory, supra note 47, at 127; Juan Forero, 3 Americans on Search Mission Killed in Colombian Plane Crash, N.Y. Times, Mar. 27, 2003, at A7 (describing the civilian contractors' assignment to rescue American citizens held in hostile regions of Colombia); Tepperman, supra note 13, at 10-11; Wayne, supra note 2 (noting the dangers associated with the flight assignments of private military employees).
n61. See Guillory, supra note 47, at 127 (noting DynCorp's involvement in firefights with FARC leftist guerillas); Rosky, supra note 6, at 911 n.141; see also GAO, Aviation Report, supra note 58 (estimating that between 1998 and 2000 alone, military contractors for the U.S. government in Latin America came under fire nearly seventy times).
n62. See Victoria Burnett et al., From Building Camps to Gathering Intelligence, Dozens of Tasks Once in the Hands of Soldiers Are Now Carried Out by Contractors, Fin. Times, Aug. 11, 2003, at 13; Catan et al., supra note 20; Forero, supra note 20; Gary Marx, U.S. Civilians Wage Drug War from Colombia's Skies, Chi. Trib., Nov. 3, 2002, at A4; see also Wayne, supra note 2 (reporting that on one occasion, contractors shot down a plane over Peru carrying American missionaries, who were mistaken for drug traffickers).
n63. Catan et al., supra note 20; Kurlantzick, supra note 20 (noting the deaths of at least eight American contractors).
n64. See, e.g., Catan et al., supra note 20 (suggesting that the lack of media attention notwithstanding the contractors' deaths is a main reason why the project in Colombia is still in existence and quoting a Colombian general as saying "Imagine if 20 American troops got killed here. Plan Colombia would be over"); Forero, supra note 20 ("My complaint about use of private contractors is their ability to fly under the radar and avoid any accountability.") (quoting Congresswoman Jan Schakowsky); Tepperman, supra note 13, at 12; Wayne, supra note 2.
n65. See GAO, Aviation Report, supra note 58, at 7-8; see also infra notes 83 and 333 (noting that the U.S. government continues to use DynCorp elsewhere in the world despite the fact that DynCorp has been a problematic contractor in the Balkans and Afghanistan too).
n66. In September, 1991, the Security Council imposed a mandatory arms embargo on all of Yugoslavia. See U.N. SCOR, 46th Sess., 3009th mtg. at 43, U.N. Doc. S/RES/713 (1991); see also Warren Christopher, In the Stream of History: Shaping Foreign Policy for a New Era (1998); Michael R. Fowler & Jessica Fryrear, Collective Security and the Fighting in the Balkans, 30 N. Ky. L. Rev. 299, 325-26 (2003); Marc Weller, The International Response to the Dissolution of the Socialist Federal Republic of Yugoslavia, 86 Am. J. Int'l L. 569, 583 (1992).
n67. See Bob Woodward, The Choice 255-56 (1996) (describing the indecision and hesitancy among European allies regarding more forceful intervention); Fowler & Fryrear, supra note 66, at 334 (noting Europe's fear that lifting the embargo would create greater instability and threaten to fracture the NATO alliance).
n68. See infra note 74 and accompanying text.
n69. See, e.g., Woodward, supra note 67, at 255-56; Steven L. Burg, Coercive Diplomacy in the Balkans: The U.S. Use of Force in Bosnia and Kosovo, in The United States and Coercive Diplomacy 57, 64 (Robert J. Art & Patrick M. Cronin eds., 2003) (describing how foreign policy in the Balkans became a critical issue in the 1996 presidential election); Roger Cohen, Why the Yanks Are Going. Yet Again., N.Y. Times, Nov. 26, 1995, at D1 (citing "fears ... of involvement in a Vietnam-like quagmire"); Elaine Sciolino, Clinton on Serbs: Pacing Shaky Ground, N.Y. Times, May 1, 1993, at A6 (noting the general reluctance on the part of the Administration to enter the fray in the former Yugoslavia).
n70. Woodward, supra note 67, at 257-60 (emphasizing how diplomatically important it was for the United States to appear neutral); John J. Mearsheimer & Stephen Van Evera, When Peace Means War, New Republic, Dec. 18, 1995, at 16 (indicating that the United States could not arm the underdog Bosnian Muslims without sacrificing its status as a neutral peace broker).
n71. See infra note 76 and accompanying text.
n72. See Sapone, supra note 50, at 24-25; Schrader, supra note 51 (explaining how the U.N. embargo compelled the United States to rely on private agents to help support its political aims in the Balkans); Mark Thompson, Generals for Hire, Time, Jan. 15, 1996, at 34-36 (noting the extensive work MPRI has performed for Croatia during the years of strife in the Balkans).
n73. Wayne, supra note 2; see also Schrader, supra note 51.
n74. See Woodward, supra note 67, at 256 (noting that the Russians would quickly arm the Serbs if the United States were seen as violating the U.N. arms embargo by supplying the besieged Bosnian Muslims and Croats); Tony Barber, Yeltsin Proposes Lifting Sanctions on Belgrade, Independent (London), July 28, 1995, at 8; Daniel Williams, Administration May Ask U.N. to Lift Arms Embargo on Bosnian Muslims, Wash. Post, Aug. 9, 1994, at A14.
n75. See Wayne, supra note 2; see also Gaul, supra note 53, at 1490 ("Without the involvement of a single American soldier ... the MPRI project strengthened Croatia's military and bolstered the nation's strategic position in the region."); Mearsheimer & Van Evera, supra note 70, at 16 (noting that the United States tacitly supported the flow of arms and military expertise to the Croatians in exchange for their support at the negotiating table).
n76. See Gaul, supra note 53; Howe, supra note 44; Roger Cohen, Bosnia Asks U.S. Arms Aid as Part of Any Peace Accord, N.Y. Times, Nov. 19, 1995, at A10 (noting that the Bosnian Muslims conditioned their acceptance of the peace agreement on the assurances of greater military parity in the Balkans); William Safire, Editorial, Balance the Power, N.Y. Times, Oct. 9, 1995, at A17 (advocating the bolstering of the Bosnian Muslims' military capacity to counterbalance that enjoyed by the Bosnian Serbs); Eric Schmitt, The Bosnian Playing Field, N.Y. Times, Oct. 30, 1995, at A8 (noting the American and European desire to enhance the military strength of the Bosnian Muslims vis-a-vis the Bosnian Serbs); see also Douglas Jehl, U.S. Looks Away as Iran Arms Bosnia, N.Y. Times, Apr. 15, 1995, at A3 (noting America's willingness to permit Iran to violate the arms embargo and bolster Bosnian capabilities even before the Dayton agreement). See generally Warren Bass, The Triage at Dayton, Foreign Aff., Sept./Oct. 1998, at 95.
n77. Sapone, supra note 50, at 25 (noting how the United States encouraged Bosnia to procure private military support well-before the lifting of the arms embargo); Bianco & Forest, supra note 30; Roger Cohen, U.S. Cooling Ties to Croatia After Winking at its Buildup, N.Y. Times, Oct. 28, 1995, at A1; Eric Schmitt, Retired American Troops to Aid Bosnian Army in Combat Skills, N.Y. Times, Jan. 15, 1996, at A1 (noting that the contracts for MPRI will be paid by Muslim nations, including Saudi Arabia); Thompson, supra note 72; Wayne, supra note 2.
n78. Wayne, supra note 2.
n79. The troops committed to the Balkans as part of the Dayton agreement would serve as neutral peacekeepers, not advocates or aides to any one side. See, e.g., Bosnia's Lingering Peace, Economist, Nov. 9, 1996, at 57 (noting the effective role of peacekeepers in Bosnia after the Dayton Accords); Mearsheimer & Van Evera, supra note 70, at 16 (arguing that the United States could not openly support the Bosnian Muslims without destroying their reputation as neutral peacekeepers and regional brokers); Norman Podhoretz, Why We Are in Bosnia, Wkly. Standard, Dec. 11, 1995, at 9 (arguing that peacekeepers should not be neutral but should bolster the position of the Muslims); Thompson, supra note 72, at 34 (describing the Clinton administration's "pledge that U.S. troops will not play an active role in rearming the Bosnians"); Jonathan Turley, Editorial, Soldiers of Fortune - At What Price?, L.A. Times, Sept. 16, 2004, at B11 (noting how contractors were used in the Balkans to exceed the congressional cap on the number of soldiers authorized to be deployed in the Balkans).
n80. See David Halberstam, The Best and the Brightest (1969) (describing how America's involvement in Vietnam began with limited participation of U.S. military advisors in what was then mainly a Vietnamese civil war and how the United States's role expanded over the years through incremental increases in commitment levels); Stanley Karnow, Vietnam: A History 267-70 (2d rev. ed. 1997); Michal R. Belknap, The Warren Court and the Vietnam War: The Limits of Legal Liberalism, 33 Ga. L. Rev. 65, 72 (1998) (noting how President Kennedy "deepened the American commitment [to the Vietnam conflict] by dispatching ... hundreds of military advisors"). See generally Jules Lobel, Covert War and Congressional Authority: Hidden War and Forgotten Power, 134 U. Pa. L. Rev. 1035, 1088-89 (1986) (describing "the dispatch of American military advisors" into a zone of conflict as having "a strong tendency to escalate into a larger American role involving United States troops").
n81. See Raymond Bonner, War Crimes Panel Finds Croat Troops "Cleansed" the Serbs, N.Y. Times, Mar. 21, 1999, at A1 (describing a brutal Croatian offensive as having been carried out with the "tacit blessing" of the United States); Wayne, supra note 2.
n82. See Graham, Croatia, supra note 13; Schrader, supra note 51 (describing the advisory and support role played by MPRI in the 1995 Croatian offensive that prompted allegations of war crimes and ethnic cleansing).
Retired Lt. Col. Roger Charles, now a military analyst, suspected that MPRI had a good deal to do with this gruesome assault on Serb villages. "No country moves from having a ragtag militia to carrying out a professional military offensive without some help... . That's not something you learn while being instructed about democratic values." Silverstein, supra note 13, at 14.
n83. See P.W. Singer, War, Profits, and the Vacuum of Law: Privatized Military Firms and International Law, 42 Colum. J. Transnat'l L. 521, 524-25 (2004) (noting also that a DynCorp supervisor was found to have videotaped himself raping two young women); John Crewdson, Contractor Tries to Avert Repeat of Bosnia Wars: Sex Scandal Still Haunts DynCorp, Chi. Trib., Apr. 19, 2003, at A3; Tepperman, supra note 13, at 11; Wayne, supra note 2.
n84. See infra Parts III.C.1 and IV.A.
n85. See also Hastings, supra note 57; McCarthy, Demand, supra note 57; T. Christian Miller, Army Gives Contract to Company in Jail Scandal, L.A. Times, Aug. 5, 2004, at A9.
n86. See Dao, supra note 2; Tepperman, supra note 13, at 10.
n87. See, e.g., Bradley Graham, Officers: Iraq Could Drain Terror War; Diversion of Afghan Forces to Gulf Raises Concerns, Wash. Post, Sept. 1, 2002, at A1; Carl Hulse, In Senate, a Call for Answers and a Warning on the Future; Focus on Iraq Criticized, N.Y. Times, Sept. 10, 2002, at A5; Glenn Kessler, Clarke's Critique Reopens Debate on Iraq War, Wash. Post, Mar. 28, 2004, at A22; Jim VandeHei, Clark Urges New Focus on Terrorist; Democratic Candidate Would Shift Forces to Hunt Bin Laden, Wash. Post, Nov. 13, 2003, at A7; see also Vincent M. Cannistraro, Editorial, Keep the Focus on Al Qaeda, N.Y. Times, Dec. 3, 2001, at A19 (warning against diverting military attention away from fighting terrorism and cautioning against devoting too many resources to fighting Saddam Hussein in Iraq); William Safire, Editorial, The View from Purgatory, N.Y. Times, June 16, 2004, at A21 (noting that promoting and protecting President Karzai's administration is essential to establishing an Islamic model of democracy); Thom Shanker, Pentagon Weighs Transferring 4,000 G.I.'s in Korea to Iraq, N.Y. Times, May 17, 2004, at A11 (noting the potential need to move U.S. troops from the volatile Korean Peninsula to Iraq).
n88. See James Brooke, The Tangled History of Karzai's Would-Be Killer, N.Y. Times, Sept. 18, 2002, at A20; John F. Burns, Afghan President Escapes Bullets; 25 Killed by Bomb, N.Y. Times, Sept. 6, 2002, at A1; Dexter Filkins, Afghan Official Is Assassinated; Blow to Karzai, N.Y. Times, July 7, 2002, at A1; Carlotta Gall, Another Assassination Attempt Is Stopped, N.Y. Times, Nov. 24, 2002, at A22.
n89. See Tepperman, supra note 13, at 12 (citing Rumsfeld as having suggested that "he can't spare the manpower to protect Afghanistan's president").
n90. See id.; see also Priest, supra note 47, at 129 (estimating 46,000 Special Forces troops in the current U.S. military's arsenal and noting that the Special Forces units were not part of the downsizing efforts that occurred throughout the military in the 1990s); Eric Schmitt & Thom Shanker, Special Warriors Have Growing Ranks and Growing Pains in Taking Key Antiterror Role, N.Y. Times, Aug. 2, 2004, at A1.
n91. See James Dao, U.S. Shifts Emphasis in Afghanistan to Security and Road Building, N.Y. Times, Nov. 12, 2002, at A14 (noting the influx of Special Forces personnel to help train Afghan security forces and help build civil infrastructure projects); Baron Gellman & Thomas E. Ricks, U.S. Concludes Bin Laden Escaped at Tora Bora Fight; Failure To Send Troops in Pursuit Termed Major Error, Wash. Post, Apr. 17, 2002, at A1; Amy Waldman, Link Between Afghanistan's North and South Is Restored, N.Y. Times, Dec. 17, 2003, at A10 (describing how the United States provided military protection to construction workers who were building a major highway in Afghanistan); see also Transcript of the Candidates' First Debate in the Presidential Campaign, N.Y. Times, Oct. 1, 2004, at A20 (quoting Senator Kerry as criticizing President Bush for pulling too many U.S. troops out of Afghanistan and "outsourcing" the job of hunting Osama Bin Laden to local Afghan warlords).
n92. See infra notes 333 and 399 and accompanying text.
n93. See, e.g., John Hendren & Mark Mazzetti, U.S. Charges Contractor over Beating of Afghan Detainee, L.A. Times, June 18, 2004, at A6; Richard A. Oppel, Jr. & Ariel Hart, Contractor Indicted in Afghan Detainee's Beating, N.Y. Times, June 18, 2004, at A1; Susan Schmidt & Dana Priest, Civilian Charged in Beating of Afghan Detainee, Wash. Post, June 18, 2004, at A1.
n94. See, e.g., Hamida Ghafour, Afghans Are Fed Up with Security Firm, L.A. Times, Sept. 27, 2004, at A3 (describing allegedly "freelance" work by Jonathan Idema, an American accused of detaining suspected al-Qaeda and Taliban members); Turley, supra note 79 (describing Idema's private prison as full of beaten and tortured detainees and commenting on Idema's claims that he had been working with the CIA).
n95. See Priest & Flaherty, supra note 4, at A1.
n96. See, e.g., Neela Banerjee & Ariel Hart, Inquiry Opens After Reservists Balk in Baghdad, N.Y. Times, Oct. 16, 2004, at A1; Jeffrey Gettleman & Douglas Jehl, Up to 12 Marines Die in Raid on Their Base As Fierce Fighting Spreads to 6 Iraqi Cities, N.Y. Times, Apr. 7, 2004, at A1; Douglas Jehl & David E. Sanger, Iraqis' Bitterness Is Called Bigger Threat than Terror, N.Y. Times, Sept. 17, 2003, at A12; Thomas E. Ricks, Probe of Reservists Underway, Wash. Post, Oct. 16, 2004, at A14 [hereinafter Ricks, Probe]; Thomas E. Ricks, Strains Felt by Guard Unit on Eve of War Duty, Wash. Post, Sept. 19, 2004, at A1 [hereinafter Ricks, Strains]; Thom Shanker & Eric Schmitt, Armor Scarce for Heavy Trucks Transporting U.S. Cargo in Iraq, N.Y. Times, Dec. 10, 2004, at A1; Steven R. Weisman, Rocky Path for Bush: Effort To Remake Iraq Hits Roadblocks, N.Y. Times, Sept. 18, 2003, at A12; Edward Wong, Iraq Chief Gives a Sobering View About Security, N.Y. Times, Oct. 6, 2004, at A1.
n97. See Editorial, Costly Troop Deficit in Iraq, N.Y. Times, Nov. 22, 2004, at A26; Shanker & Knowlton, supra note 22; Spiegel, supra note 22.
n98. See Dao, supra note 22; Carl Hulse, Military Draft? Official Denials Leave Skeptics, N.Y. Times, July 3, 2004, at A1; Krugman, supra note 22; Thom Shanker, Need for Draft Is Dismissed by Officials at Pentagon, N.Y. Times, Oct. 31, 2004, at A22.
n99. See Gordan, supra note 22; Nicholas D. Kristof, Editorial, Brother, Can You Spare A Brigade?, N.Y. Times, Dec. 11, 2004, at A19; Elain Sciolino, Spanish Premier Says Troops Will Not Return to Iraq, N.Y. Times, May 7, 2004, at A3; see also infra note 417 and accompanying text.
n100. See, e.g., Cooper, supra note 22.
n101. See id.; Mary Ann Fergus, Iraq's Other Toll, Houston Chron., Oct. 24, 2004, at A1; von Hoffman, supra note 20.
n102. See infra notes 145-61 and accompanying text.
n103. See The Baghdad Boom, Economist, Mar. 27, 2004, at 56; Cooper, supra note 22; Dao, supra note 4; Priest & Flaherty, supra note 4; see also Barstow et al., supra note 4. Barstow and his colleagues write:
Far more than in any other conflict in United States history, the Pentagon is relying on private security companies to perform crucial jobs once entrusted to the military. In addition to guarding innumerable reconstruction projects, private companies are being asked to provide security for the chief of the Coalition Provisional Authority, L. Paul Bremer III, and other senior officials; to escort supply convoys through hostile territory; and to defend key locations, including 15 regional authority headquarters and even the Green Zone in downtown Baghdad, the center of American power in Iraq.
n104. See Priest, supra note 4.
n105. For example, in March 2004, four employees were similarly pinned down by insurgents in Fallujah and were killed. Id.; see also Barstow et al., supra note 4; Sewell Chan, U.S. Civilians Mutilated in Iraq Attack, Wash. Post, Apr. 1, 2004, at A1; Dana Priest & Mary Pat Flaherty, Slain Contractors Were in Iraq Working Security Detail, Wash. Post, Apr. 2, 2004, at A16.
n106. See Article 15-6 Investigation of the 800th Military Police Brigade ("Taguba Report"), at http://www.publicintegrity.org/docs/abughraib/taguba_report.pdf (last visited Dec. 12, 2004).
n107. See Article 15-6, Investigation of the Abu Ghraib Detention Facility and 205th Military Intelligence Brigade ("Fay Report"), at http://news.findlaw.com/hdocs/docs/dod/fay82504rpt.pdf (last visited Dec. 24, 2004).
n108. See Final Report of the Independent Panel To Review DoD Detention Operations ("Schlesinger Report"), at http://www.c-span.org/pdf/prisonerfinalreport.pdf (last visited Feb. 24, 2005).
n109. See supra notes 106-08; see also Editorial, Abuse by Outsourcing, Wash. Post, May 26, 2004, at A26; Deborah Avant, What Are Those Contractors Doing in Iraq?, Wash. Post, May 9, 2004, at B1; Joel Brinkley, Army Policy Bars Interrogations by Private Contractors, N.Y. Times, June 12, 2004, at A5; Joel Brinkley, U.S. Civilian Working at Abu Ghraib Disputes Army's Version of His Role in Abuses, N.Y. Times, May 26, 2004, at A5; Brinkley & Glanz, supra note 8, at A15; Ariana Eunjung Cha & Renae Merle, Line Increasingly Blurred Between Soldiers and Civilian Contractors, Wash. Post, May 13, 2004, at A1 (noting that contractors in Abu Ghraib were known to exert considerable influence over the Army's rank and file); Joshua Chaffin, Contract Interrogators Hired To Avoid Supervision, Fin. Times, May 21, 2004, at 9; Sewell Chan, U.S. Official: Abuse Allegations Are "a Big Deal": Charges Involving Army-Run Prison in Iraq Seen as Setback, Wash. Post, May 3, 2004, at A16; Hersh, supra note 4; Seymour M. Hersh, Torture at Abu Ghraib, New Yorker, May 10, 2004, at 42; David Johnston & Neil A. Lewis, U.S. Examines Role of C.I.A. and Employees in Iraq Deaths, N.Y. Times, May 6, 2004, at A16; Renae Merle, CACI and Titan Sued Over Iraq Operation; Legal Center Representing Prisoners, Wash. Post, June 10, 2004, at E3; Renae Merle, Contractor Investigated by Justice, Wash. Post, May 22, 2004, at A17 (describing allegations that CACI employees instructed the military police in interrogation tactics that the contractors "knew ... equated to physical abuse"); James Risen, Command Errors Aided Iraq Abuse, Army Has Found, N.Y. Times, May 3, 2004, at A1.
n110. Merle, supra note 4, at A17; Scott Shane, Chalabi Raid Adds Scrutiny to Use of U.S. Contractors, Balt. Sun, May 30, 2004, at 1A.
n111. See Singer, supra note 20; Tepperman, supra note 13, at 10-12; Wayne, supra note 2; see also Rosky, supra note 6, at 908 (characterizing the private military industry as insisting that its contractors largely confine themselves to defensive and logistical tasks).
n112. Thom Shanker & David E. Sanger, The Struggle for Iraq: Contingencies; Pentagon Drafts Iraq Troop Plan To Meet Violence, N.Y. Times, Apr. 21, 2004, at A1 (noting that estimates in the Spring of 2004 indicated that American forces in Iraq were short by about 20,000 the number of troops requested by General Abizaid, head of the U.S. Central Command).
n113. See Carlos H. Conde, The Reach of War; Manila Starts Withdrawing Troops from Iraq; U.S. Criticizes Step, N.Y. Times, July 15, 2004, at A7; Shanker & Sanger, supra note 112 (noting the withdrawal of troops in Iraq by Spain, Honduras, and the Dominican Republic).
n114. See Rajiv Chandrasekaran & Scott Wilson, Marines Begin to Cede Control of Restive Fallujah, Wash. Post, May 2, 2004, at A1.
n115. See supra note 57; see also supra note 85.
n116. Within a matter of one hundred days, over 800,000 Tutsis were slaughtered. See Michael Barnett, Eyewitness to a Genocide: The United Nations and Rwanda 1 (2002); Samantha Power, "A Problem from Hell": America and the Age of Genocide 362, 381-82 (2002).
n117. See Dep't of Defense, Summary - Report to Congress on U.S. Military Activities in Rwanda, 1994 - August 1997, available at http://www.defenselink.mil/pubs/rwanda/summary.html (last visited May 4, 2004) (noting Ronco's participation in dog de-mining program as part of humanitarian relief); see also Victoria Brittain, Absolute Minefield, Guardian (London), Aug. 27, 1994, at T20 (describing Ronco's contractual responsibilities in Rwanda, including detecting mine fields); Pentagon Provides Dogs To Detect Landmines in Rwanda, Africa News, Mar. 1996 (same).
n118. See Milliard, supra note 23, at 18-19 (noting that while it is "unlikely that any modern [private military company, or "PMC"] could have diffused the Rwandan crisis in mid-1994 ... [a] capable and willing PMC could have seized, disabled, or simply jammed Hutu-controlled Radio Mille Collines early on to prevent further anti-Tutsi propaganda ... [and] intervened to prevent or at least discourage those responsible for the organized but small-scale assaults, rapes, and murders that began in 1990"); Pape & Meyer, supra note 2 (describing Executive Outcome's early and unsuccessful pitch to the Clinton administration to provide services to stabilize Rwanda).
n119. See David Halberstam, War in a Time of Peace 276 (2001) ("The genocide succeeded ... because it took place in a moral and political vacuum."); Power, supra note 116 (noting the complete lack of urgency from the West to intervene); Alison L. Des Forges, Shame: Rationalizing Western Apathy on Rwanda: Alas, We Knew, Foreign Aff., May/June 2000, at 141 (describing how western leaders refused to intervene at a sufficiently early junction to prevent the mass slaying of the Tutsis); Chaim Kaufmann, See No Evil: Why America Doesn't Stop Genocide, Foreign Aff., July/Aug. 2002, at 142-43 ("The United States not only did not halt the killing but actively prevented other [more] willing powers from taking effective action.").
n120. Halberstam, supra note 119, at 277.