Author: JURIST – Paper Chase

[JURIST] The US Federal Communications Commission (FCC) announced Thursday that it will move forward with the first phase of its National Broadband Plan in 2010. The 2010 Broadband Action Agenda lays out the steps the agency plans to take in order to make broadband internet access more available in the country. The announcement follows a federal court ruling Tuesday that the FCC lacks authority to enforce net neutrality, a policy considered vital to the plan by many. FCC Chairman Julius Genachowski said the plan could proceed despite the ruling:
The Commission’s Bureaus and Offices have already begun executing on the strategy the National Broadband Plan lays out . . . The court decision earlier this week does not change our broadband policy goals, or the ultimate authority of the FCC to achieve those goals. The court did not question the FCC’s goals; it merely invalidated one technical, legal mechanism for broadband policy chosen by prior Commissions.The 2010 agenda also outlines steps toward numerous goals unrelated to net neutrality, including reclamation of 500 megahertz of open-air spectrum for mobile broadband applications, the creation of a public safety wireless broadband network and improved access to broadband service in rural and other underserved areas.The FCC sent the plan to Congress for approval last month, seeking approval to enact regulations to update the communications infrastructure in the US and make broadband service available to millions more Americans. The policy of net neutrality is unanimously supported by the FCC’s commissioners and is considered essential to the its goal of an open flow of information over the internet regardless of the amount of revenue generated by the information. The policy has been vigorously opposed by telecommunications companies Verizon, AT&T and Comcast, which argue that such rules would inhibit their ability to effectively manage Internet traffic. Other notable goals of the plan include providing 100 million households with affordable 100 megabits-per-second internet service and ensuring that all children are literate in digital technology by the time they leave high school.

[JURIST] Italian prosecutors on Friday sought to indict Italy Prime Minister Silvio Berlusconi on fraud and embezzlement charges involving his media company, Mediatrade, despite a new law granting the executive temporary immunity. The law passed in March and allows cabinet officials to postpone criminal proceedings against them for up to 18 months if the charges constitute a “legitimate impediment” to performing public duties. Prosecutors claim that while Berlusconi was head of Mediatrade, it sold television rights at inflated prices to a US producer, resulting in illegitimate gains of approximately $47 million. Prosecutors also sought to charge Berlusconi’s son, Pier Silvio Berlusconi, and nine others in connection to the case. Berlusconi’s lawyers deny that he was in control of Mediatrade during the deals, and have not indicated whether they will invoke the immunity law.
The law granting Berlusconi immunity was approved by the Chamber of Deputies in February. In January, hundreds of Italy’s judges walked out of their courtrooms to protest the passage of legislation that placed strict time limits on the trial and appeals process. Both laws have been criticized as being tailored for Berlusconi’s benefit. He currently faces corruption and tax fraud trials, both of which have been postponed. The leader has been previously acquitted of false accounting and bribery, and has had other charges against him dropped.

[JURIST] The UK Parliament on Thursday approved legislation authorizing the suspension of internet service for those who repeatedly download copyrighted material illegally. The act also received Royal Assent and is now law. The Digital Economy Bill calls on internet service providers (ISPs) to block download sites, reduce a user’s broadband speeds, and ultimately shut down a user’s internet access in order to prevent piracy of copyrighted materials. The bill, known as a three-strikes law, imposes stricter penalties on repeat digital offenders than had previously existed, and has received a great deal of public criticism. Certain ISPs have even threatened to not comply with the law, but MPs who support it say it is a necessary step to protect the creators of digital content.
Online piracy has assumed increasing importance in the eyes of legislators across Europe, and many countries, including France, have enacted similar legislation. A recent report, however, suggests that the French anti-piracy bill may actually lead to increased piracy. The French bill was approved by the Constitutional Court in October after being given final approval by the French Parliament the previous month. Under the French law, the government could send notices to Internet service providers to terminate an individual’s internet access for up to one year after a third violation of intellectual property laws for downloading or sharing movies and music.

[JURIST] The European Court of Human Rights (ECHR) ruled Thursday that Azerbaijan violated parliamentary candidate Namat Aliyev’s rights to stand freely and fairly in the country’s 2005 elections. Aliyev alleged that the government violated his rights under Article 3 of Protocol 1 to the European Convention on Human Rights, which ensures the free expression of the people in the selection of a country’s legislature. Aliyev accused the Azerbaijan electoral commission and courts of failing to thoroughly investigate irregularities and breaches of electoral law in the election. The ECHR found:
What was at stake in those proceedings was not only the alleged infringement of the applicant’s individual rights but also, on a more general level, the State’s compliance with its positive duty to hold free and fair elections. Therefore, even assuming that the courts in the present case might have been unable to decide the case solely on the basis of the evidence submitted by the applicant, the material put before them was nevertheless strong enough to require them to take additional steps to obtain more information and verify the accuracy of the applicant’s allegations which cast doubt on the free and fair character of the elections in his constituency.The ECHR found support for its decision in a report by the Organization for Security and Co-operation in Europe on the elections. The ECHR ordered Azerbaijan to pay a 7,500 Euro fine.The Aliyev ruling is the 24th ECHR decision against Azerbaijan and comes as the country prepares to again hold parliamentary elections in November. Earlier this month, Popular Front Party leader Ali Karimli wrote an editorial expressing concerns about the political situation in Azerbaijan. In December 2008, a referendum was approved that eliminated term limits for the country’s president. Incumbent president Ilham Aliyev was elected president in 2003 following the death of his father Heydar Aliyev, a prominent leader in the the oil- and gas-rich former Soviet republic since 1969. In October 2008, I. Aliyev was reelected with nearly 90% of the vote, though the election was boycotted by opposition parties and was internationally criticized for failing to meet democratic standards. Aliyev has been accused by members of the press of heavy-handed repression of the media.

[JURIST] Former South Korean Prime Minister Han Myeong-sook was acquitted Friday of bribery charges by the Seoul Central District Court. Han was accused of accepting $50,000 from former Korea Express CEO Kwak Young-wook in 2007 in exchange for helping him become president of Korea South-East Power Co., an affiliate of the state-run Korea Electric Power Corporation. The prosecution had relied on Kwak’s testimony as the primary evidence against Han, but the court found his statements contradictory and unconvincing. It also found Kwak guilty of embezzlement charges unrelated to the bribery charges against Han. Han’s supporters hope that the acquittal will help the opposition leader politically, as she plans to run for mayor in upcoming June elections. The prosecution plans to appeal the decision.
The acquittal temporarily ends legal troubles for the former prime minister. In December, Han was indicted for bribery the week after a court issued a warrant for her arrest. Han served as the country’s first female prime minister under president Roh Moo-hyun. Roh, who was himself the target of a bribery investigation, died in May from an apparent suicide. Shortly before his death, prosecutors had questioned Roh on suspicion that he accepted up to $6 million in bribes from Park Yeon-cha, a financial supporter who is also CEO of a shoe manufacturing company.

[JURIST] Justice John Paul Stevens of the US Supreme Court announced Friday that he plans to step down at the end of the court’s 2009 term this summer. In a letter to President Barack Obama, Stevens wrote, “it would be in the best interests of the Court to have my successor appointed and confirmed well in advance of the commencement of the Court’s next Term.” There had been much speculation about Stevens’s possible retirement, and leading candidates for his replacement reportedly include Solicitor General Elena Kagan and federal appellate Judges Merrick Garland and Diane Wood.
Stevens, 89, was nominated to the Supreme Court by President Gerald Ford and was seated in December 1975. He previously served on the US Court of Appeals for the Seventh Circuit. Stevens is the court’s oldest and most senior member and has served as the leader of the court’s liberal bloc. His retirement gives Obama his second opportunity to nominate a Supreme Court justice, following last year’s retirement of Justice David Souter and confirmation of Justice Sonia Sotomayor.

[JURIST] US district court judge James Robertson granted Congress additional time Thursday to approve a $3.4 billion settlement against the government in a class action lawsuit brought for its alleged mismanagement of American Indian trust funds. The delay, the third since the settlement was reached in December, moves the congressional approval date from April 16 to May 28. Though Roberston approved the latest delay, he warned government lawyers that this is the last delay he will grant, stating that he will summon Secretary of the Interior Ken Salazar if Congress fails to act within the time granted. Pending congressional approval, the settlement will be the largest American Indian claim ever approved by the US government and will end a fourteen year legal battle.
Congress established the Indian trust in 1887 to hold proceeds from government-arranged leases of Indian lands. In July, the US Court of Appeals for the District of Columbia ordered the US Department of Interior to provide an accounting of the trust to the court. In 2008, Roberston rejected plaintiffs’ claims that the government had engaged in fraud, but held that the DOI “unreasonably delayed” the accounting of billions of dollars of American Indian money. The case went to trial in June 2008, after the plaintiffs rejected a 2007 settlement proposal from the government.

[JURIST] The Appeals Chamber of the International Criminal Tribunal for the former Yugoslavia (ICTY) on Thursday denied the latest attempt by former Bosnian Serb leader Radovan Karadzic to delay his war crimes trial. Karadzic argued that there had been a violation of his right to a fair hearing because the court had rejected previous evidentiary challenges. The ICTY dismissed Kardzic’s motion, reasoning that:Until the final Judgement is issued in this case, the parties can only speculate as to what evidence the Chamber will admit, how that evidence will be evaluated, and what conclusions will be drawn from it. Should the Chamber base any conviction of the Accused solely on witness evidence that has not been subject to cross-examination, it will be for the Accused to raise that issue on appeal at the appropriate time.
For these reasons, the Chamber is not satisfied that there has been any violation of the Accused’s right to a fair trial which would justify a stay of the proceedings. Karadzic’s trial is set to resume on Tuesday.Last month, Karadzic lost another motion to postpone his war crimes trial on charges related to crimes committed during the 1992-1995 Bosnian conflict. Karadzic claimed that a February ruling increasing the remuneration for his defense lawyers should also give him extra time to prepare for his case. Earlier in March, the ICTY heard opening statements in Karadzic’s war crimes trial. Karadzic claimed that attacks against Bosnian Muslims were “staged,” denying any involvement in war crimes.. In February, the ICTY rejected Karadzic’s imposition of a court-appointed defense lawyer, claiming the right to legal assistance of his own choosing. Karadzic is defending himself against 11 counts, including genocide and murder.

[JURIST] A Thai court on Friday issued arrest warrants for at least 17 high-profile protesters in an attempt to put down violent protests. Among the accused are top leaders of the the United Front for Democracy Against Dictatorship, also known as red shirts. The warrants are in addition to warrants issued Thursday for seven high-level protesters accused of being among a large group of protesters that entered the Parliament building during protests Wednesday. Prime Minister Abhisit Vejjajiva said he hopes that the arrest of the high-profile leaders will cause other protesters to disperse.
On Wednesday, Vejjajiva declared a state of emergency, giving the government increased ability to detain individuals and censor the media. The declaration came just days after a Thai court dismissed the government’s application for an injunction against protesters gathered in Bangkok’s business district. The injunction would have ordered protest organizers to lead the group out of the area and would have banned rallies in 11 other areas. The court denied the request stating that the Internal Security Act, approved by the Thai Cabinet in March, already gave the government eviction powers. The red shirts are supporters of former prime minister Thaksin Shinawatra, who was removed from power in 2006 following a coup. The group is demanding that Abhisit dissolve parliament and call new elections. Last April, Abhisit declared a state of emergency in Bangkok and several provinces following a similar outbreak of protests calling for his resignation.

[JURIST] Turkish politician and Kurdish rights activist Leyla Zana was sentenced Thursday to three years in prison for spreading terrorist propaganda. Zana was convicted by a court in the city of Diyarbakir for two speeches delivered at the Kurdish political congress and protest in 2008. Zana has previously been convicted for spreading propaganda under Turkey’s anti-terrorism laws, most recently facing a 10-year sentence in 2008 for supporting the Kurdistan Worker’s Party (PKK), a militant Kurdish nationalist group. She remains free pending appeal. Turkey has been accused of using its anti-terrorism laws to suppress Kurdish nationalists. The Kurdish Human Rights Project (KHRP) criticized Turkey’s anti-terrorism laws saying that though they were passed due to heightened security concerns, they have hindered freedom of expression, association, and have been used to suppress certain groups like the Kurds.
Zana was the first women elected to Turkey’s parliament in 1991, and shortly thereafter there were calls for her arrest when she read the Parliamentary Oath in Kurdish. She was sentenced to 15 years in prison, along with other members of her Democracy Party, when the party was banned in 1994. She served 10 years in prison until her conviction was overturned and she was freed from prison in 2004. In calling for a peaceful settlement to issues of Kurdish rights, she had been nominated for the Nobel Peace Prize in 1995 and 1998, and was awarded the Sakharov Prize in 1995.

[JURIST] US Attorney General Eric Holder announced Thursday that Spain has agreed to resettle four detainees from the Guantanamo Bay detention facility. The four detainees are in addition to a Palestinian detainee transferred to Spain earlier this year. The governments have yet to decide which detainees will be transferred. Holder met with Spanish Prime Minister Jose Luis Rodriguez Zapatero during his visit to Spain to discuss issues of counter-terrorism and combating international organized crime. Holder also signed a Memorandum of Understanding with Prosecutor General Conde-Pumpido to strengthen the ability of law enforcement officials to work cooperatively within each others’ countries.
In February, Spanish Foreign Minister Miguel Angel Moratinos initially agreed to accept five detainees after the government had previously agreed to accept only two detainees, one Yemeni and one Palestinian, in response to a June request by the Obama administration. Moratinos indicated that Spain was willing to increase the number of detainees accepted in order to help remedy what it sees as an unacceptable situation at the detention facility. Spain joins a growing list of countries that have recently accepted transfers, including Latvia, Switzerland, Slovakia, Algeria, Afghanistan, Palau , Bermuda, Albania, and Somaliland.

[JURIST] Former Guantanamo Bay detainee Adel Hassan Hamad filed suit in the US District Court for the Western District of Washington Wednesday against the US government and more than a dozen government officials. Hamad, a Sudanese aid worker captured in Pakistan in 2002, claims he was tortured during his time at Guantanamo Bay. A lawyer for Hamad claimed in 2007 that he was not guilty of any crimes and that the government had obstructed lawyers’ attempts to clear his name. It is unclear how much compensation Hamad is seeking.
Hamad was among a group of former detainees who announced in Sudan in 2008 that they planned to sue the US government in US courts. The US government released Hamad in 2007. Earlier that year, Hamad’s lawyers filed an affidavit signed by an unnamed Army officer accusing the government of bias in its treatment of detainees.

[JURIST] A group of citizens from Kinston, North Carolina, on Wednesday filed suit in the US District Court for the District of Columbia claiming that Section 5 of the federal Voting Rights Act (VRA) unconstitutionally discriminates on the basis of race. Section 5 requires certain voting districts to seek federal approval before making any changes to voting procedure, in order for the government to ensure that the changes do not adversely affect minority voting rights. Kinston had sought to institute a non-partisan voting system, but was denied approval to do so by the Department of Justice (DOJ). The DOJ found that even though the system was not intended to harm minority interests, it would have the effect of reducing minority political representation. The group filing the complaint argues that Section 5 is unconstitutional because it does not provide the same protection for non-minority groups and because its original rationale has now expired.
In June, the US Supreme Court upheld Section 5 without reaching its constitutional validity. The court ruled 8-1 in Northwest Austin Municipal Utility District Number One v. Holder that the VRA permits covered municipalities to “bail out” from the preclearance requirement of Section 5 if they can establish a history of compliance with the VRA, but declined to rule on the constitutionality of Congress’s 25-year extension of the section in 2006. The city of Kinston did not seek the bail out option.

[JURIST] The Supreme Court of the Philippines ruled Thursday that a prominent gay rights organization may field candidates in the upcoming national elections as an accredited political party. The decision invalidates an order issued by the Commission on Elections (Comelec) in November that rejected a bid for party recognition by Ang Ladlad. In denying Ang Ladlad’s original petition, Comelec cited the group’s ” immorality which offends religious beliefs.” The court, however, determined that the policy violated Article III, Section 5 of the Philippines Constitution, which has previously been interpreted to mandate “government neutrality in religious matters.” The decision stated:e hold that moral disapproval, without more, is not a sufficient governmental interest to justify exclusion of homosexuals from participation in the party-list system. The denial of Ang Ladlad’s registration on purely moral grounds amounts more to a statement of dislike and disapproval of homosexuals, rather than a tool to further any substantial public interest. Respondent’s blanket justifications give rise to the inevitable conclusion that the Comelec targets homosexuals themselves as a class, not because of any particular morally reprehensible act.Having met all legal requirements for certification as a party, the court ordered that Ang Ladlad be permitted to fully participate in the May elections.The court issued a temporary restraining order against Comelec in January, requiring the body to include Ang Ladlad on the list of official parties until a decision on the case’s merits could be reached. In December, Comelec again rejected Ang Ladlad’s request for accreditation. Officials voting against the group reiterated their moral concerns, and stated that their interests are sufficiently represented legislatively.

[JURIST] Pakistan’s National Assembly on Thursday unanimously passed a constitutional amendment that would curtail the powers of the president. The 18th Amendment Bill would reverse the expansion of presidential powers under former military leader Pervez Musharraf by transferring presidential powers to the office of the prime minister, effectively reserving the presidency as a figurehead. Among other changes, the president would no longer have the power to dissolve parliament, dismiss the prime minister, or appoint the chief of the armed forces. The bill must be approved by a two-thirds majority of the Senate and be signed by President Asif Ali Zardari before becoming law.
The introduction of the bill comes amid controversy over reopening corruption investigations against Zardari. Last week, Pakistan’s Attorney General Anwar Mansoor announced his resignation over controversy surrounding a Supreme Court order to investigate corruption allegations against Zardari. Earlier that week, Swiss authorities denied a request from Pakistan’s National Accountability Bureau, refusing to reopen a corruption investigation against Zardari. Aides to Zardari believe that presidential immunity protects him from prosecution, even after the Supreme Court overturned an amnesty law implemented by Musharraf. The amnesty was signed by Musharraf as part of a power-sharing accord allowing former Pakistani prime minister Benazir Bhutto to return to the country despite corruption charges she had faced.

[JURIST] Former Kyrgyz foreign minister Roza Otunbayeva announced Thursday that she will lead an interim government in Kyrgyzstan after violent protests Wednesday apparently ousted president Kurmanbek Bakiyev and his administration. Otunbayeva, leader of the Social Democratic Party of Kyrgyzstan, urged Bakiyev to resign and said that her temporary government will rule for six months until the country holds democratic elections. Bakiyev, who fled the capital city Wednesday, said in a statement Thursday that he will not resign. Also Thursday, UN Secretary-General Ban Ki-moon announced that he will send an envoy to Kyrgyzstan and encouraged calm in the unstable country. Ban said in a statement that “while freedom of assembly is an essential element of any democratic society, the rule of law must be respected.” Rights groups have also urged leaders to respect human rights.
The violent protests, which appear prompted in part by a drastic increase in utility costs, began late Tuesday night in the city Talas then spread throughout the country Wednesday. Reports vary as to the number of citizens killed during the protests, with Kyrgyz opposition officials reporting more than 60 deaths and more than 400 injuries. Interior Minister Moldomus Kongantiyev was killed during an attack by protesters, while former prime minister and presidential candidate Almazbek Atambayev and former parliament speaker Omurbek Tekebayev were among the many opposition leaders arrested. The protesters also took control of the country’s television station, and approximately a thousand people surrounded the prosecutor-general’s office and set it on fire. The protests came a week after Ban called on Kyrgyzstan to protect all forms of human rights. The statements follow recent events in the country that include the shutdown of an opposition newspaper, a police raid on a local television station that resulted in the station being taken off the air, and the confiscation of computers from a video web portal based on allegations of pirated software use.

[JURIST] Texas Attorney General Greg Abbott announced Wednesday that five additional states will join in a lawsuit challenging the constitutionality of the recently enacted Patient Protection and Affordable Care Act. The five states – Indiana, North Dakota, Mississippi, Nevada, and Arizona – will join 13 other states in a legal battle that began last month 23 when the complaint seeking an injunction and declaratory relief was filed in a Florida federal court. Abbott commented on the impact of the inclusion of additional states and voiced his concern over the potential effects the health care legislation will have on Texas and the US:
No public policy goal – no matter how important or well-intended – can be allowed to trample the protections and rights guaranteed by the U.S. Constitution. The federal health care legislation violates our Constitution, imposes an unprecedented mandate on individual Texans, and will require the Texas taxpayers to spend billions of additional dollars on health care programs. The addition of five new states to our bipartisan legal challenge reflects broad, nationwide concern about the constitutionality of this sweeping and unprecedented federal legislation.The other states involved in the suit are Florida, South Carolina, Nebraska, Pennsylvania, Louisiana, Washington, Colorado, Michigan, Utah, Alabama, South Dakota, and Idaho. Among the allegations in the suit are violations of Article I and the Tenth Amendment of the Constitution, committed by levying a tax without regard to census data, property, or profession, and for invading the the sovereignty of the states. The plaintiffs also assert that the law should not be upheld under the commerce clause. Last month, Idaho Governor CL Otter signed a bill barring the federal mandate to purchase health insurance. Virginia Governor Bob McDonald has indicated that he will sign a similar bill recently passed by the Virginia legislature. President Barack Obama signed the Health Care and Education Reconciliation Act into law last week, which addressed concerns raised by the original bill, including provisions to help uninsured Americans pay for coverage, concerns over the effects to Medicare, and lowering the penalty for not buying insurance.

[JURIST] US President Barack Obama and Russian President Dmitry Medvedev on Thursday signed the so-called New START treaty, pledging to reduce their countries’ nuclear warheads by about 30 percent. Under the terms of the treaty and its protocol, both countries would only be allowed to deploy 1,550 strategic warheads, a decrease from the 2,200 currently permitted. The treaty would also re-establish mechanisms to allow each party to inspect the other’s nuclear arsenal. Speaking at a joint press conference after signing the treaty, Obama said that “hile the New START treaty is an important first step forward, it is just one step on a longer journey,” reiterating his vision of a world without nuclear arms. Medvedev praised the treaty as “a very important step to build trust and understanding between our two countries.” The treaty must be ratified by both countries before entering into force.
The treaty agreement, reached in February, is the first nuclear agreement between the two nations in nearly 20 years. The US State Department began negotiating the treaty with Russia in 2009. Nuclear disarmament between the US and Russia, whose nuclear arsenals comprise 95 percent of the world’s nuclear weapons, languished during the Bush administration. The treaty is considered a key part of easing tensions between the two countries, which reached a high point after the 2008 Georgia conflict.

[JURIST] The Kenyan Ministry of Foreign Affairs declared Wednesday that Kenya’s government is attempting to secure the release of Kenyan native Mohammed Abdumalik, who is currently detained at Guantanamo Bay. The news was revealed in a letter to Abdulmalik’s family, informing them that the government will ask the United States to release the detainee. Abdulmalik’s family filed a $30 million lawsuit against the Kenyan government last year, claiming that Abdulmalik was illegally detained, tortured, and rendered to US authorities.
Abdulmalik was originally arrested by the Kenyan Anti-terrorism Police Unit in Mombasa in 2007 in connection with the 2002 bombing of a resort hotel and a failed attempt to shoot down an Israeli charter plane. He was then taken into US custody and eventually transferred to Guantanamo where he allegedly confessed to the crimes, although his Combatant Status Review Tribunal report is still classified. British human rights group Reprieve, which has helped Abdulmalik’s family, stated that the case points out the illegal means by which detainees have ended up in Guantanamo. Kenyan authorities deny arresting Abdulmalik, whom they claim is not a Kenyan citizen, and handing him over to the US military.

[JURIST] Human Rights Watch (HRW) called Wednesday for an investigation into alleged war crimes committed during the recent conflict between the government of Yemen and Shiite Huthi Rebels. According to HRW’s report, “All Quiet on the Northern Front?: Uninvestigated Laws of War Violations in Yemen’s War with Huthi Rebels,” the February truce between the factions has not resulted in any meaningful inquiry into air strikes on populated villages, indiscriminate violence, summary executions, and child soldiers, among other alleged violations:
The elements of this shaky truce – the sixth in almost as many years – do not include investigations into alleged violations of the laws of war. … The continuing failure of both the Yemeni government and the Huthi rebels to investigate alleged violations by their forces prevents perpetrators from being held to account, denies compensation to victims of abuses, and complicates efforts to reach a long-term political settlement.HRW also accused the UN of failing to provide an organization tasked with monitoring the crisis and the possible human rights abuses. HRW is petitioning concerned governments to encourage Yemen to increase access and transparency in order to hold perpetrators liable for crimes.The Yemeni war against them Shiite Huthi Rebels, termed the Sa’dah insurgency, began in June 2004 with the uprising lead by Zaidi religious leader Hussein Badreddin al-Houthi against the Yemeni government. That time period was marked with five distinct phases or cycles of violence. Yemen has alleged that the Huthi Rebels have continuously received support from Iran and other sympathetic governments. The lack of transparency and the remoteness of fighting make it difficult to ascertain causalities in which estimates range from the hundreds to the thousands.