The Defendant, Emmanuel Constant, was the leader of FRAPH, a paramilitary organization that used murder, torture, and rape as tools of political suppression during and after the insurgency that overthrew Jean Bertrand Aristide’s government. In this case, three women “Jane Does” sued Constant—claiming that their rape and torture occurred as a result of the systematic rule of terror and suppression by the FRAPH organization under Constant’s leadership.

The Focal Point’s Role

The Focal Point collaborated on this case with the attorneys of SNR Denton and The Center for Justice & Accountability. The Focal Point did trial strategy work with counsel and created graphics to help illustrate how the attacks on the Plaintiffs were the result of an organized campaign led by the Defendant to suppress supporters of former Haitian President Aristide. The Focal Point also worked with the attorneys and experts to create graphics to outline the suffering and effects of the attacks, to help the judge rule in favor of the Plaintiffs, and award appropriate damages.


Judge Sydney H. Stein of the U.S. District Court of the Southern District of New York found in favor of Jane Does I, II, and III and ordered Emmanuel Constant to pay $19 million in compensatory and punitive damages for attacks on their persons in Haiti during the early 1990s under the terms of the federal Alien Tort Statute and the Torture Victim Protection Act. As a result of their efforts in this civil rights case, both Ivor Samson and Moira Feeney received CLAY Awards (California Lawyer/Attorney of the Year) from California Magazine in 2007. The Focal Point is very proud of its commitment to this important case.


US District Court for the Southern District of New York (New York, NY)

The Focal Point’s Clients

SNR DentonIvor Samson
Jessica Woelfel

Center for Justice and Accountability

Moira Feeney