There is confusion in the doctrine of the responsibility of states for denial of justice, particularly where the “denial” consists in failure to operate the machinery of criminal justice.

The Reagan administration’s arguments purporting to justify the invasion of Grenada under international law must not be allowed to inveigle the American people into supporting this violent intervention into the domestic affairs of another independent state. Throughout the 20th century, the U.S. Government has routinely concocted evanescent threats to the lives and property of U.S. nationals as pretexts to justify armed interventions into sister American states. The transparency of these pretexts was just as obvious then as it is now. The Reagan administration has not established by means of clear and convincing evidence that there did in fact exist an immediate threat to the safety of U.S. citizens in Grenada. Even then, such a threat could have justified only a limited military operation along the lines of the Israeli raid at Entebbe for the sole purpose of evacuating the major concentration of U.S. nationals at the medical college.

On February 17, 1992, police found the body of Ruth Dickie in her apartment in Arlington County, Virginia. She had been stabbed to death and her assailant had attempted to rape her. Six months later, Angel Francisco Breard was apprehended in the course of an attempted rape in Washington, D.C., and also became a suspect in Dickie’s murder, for which he was subsequendy indicted. As summarized in the appellate review of Breard’s conviction by the Supreme Court of Virginia,