La Muchacha respondona: Reflections on the Razor's edge between crime and human rights

Human Rights Quarterly

Volumn 27, Issue 2, 2005, Pages 597-624

  Godoy, Angelina Snodgrass ^a  

^a UNIVERSITY OF WASHINGTON   (United States)

Author keywords

[No Author keywords available]

Indexed keywords

CRIME; HUMAN RIGHTS; WOMENS STATUS;

EID: 20044381546     PISSN: 02750392     EISSN: None     Source Type: Journal    
DOI: 10.1353/hrq.2005.0018     Document Type: Review

References (106)

1. Amnesty International, AMR 34/001/2002, Guatemala's Lethal Legacy: Past Impunity and Renewed Human Rights Violations (2002) [hereinafter Guatemala's Lethal Legacy], available at web.amnesty.org/library/ Index/engAMR340012002?OpenDocument&of=COUNTRIES%5CGUATEMALA.
2. Lt. Col. Carlos Ochoa Ruiz was indicted in 1990 by a US federal grand jury for shipping half a metric ton of cocaine, worth some $7.5 million wholesale, from Western Guatemala to Tampa, Florida. He was the first Guatemalan military officer for whom the US requested extradition. Two days after González's murder, the court reversed its earlier ruling and brought the extradition proceedings to a halt; Ochoa remains in Guatemala. (For more on this case, see Frank Smyth, Has Guatemala Become the Cali Cartel's Bodega?, Wall St. J., 10 Mar. 1995, at A15;
3. Frank Smyth, Genocide, and Drug-Trafficking Too, 5 Mar. 1999, available at www.salon.com/news/1999/03/05 news.html.
4. Myrna Mack was a Guatemalan anthropologist whose research focused on the indigenous communities displaced by the army's brutal counterinsurgency strategies. After having experienced repeated surveillance, she was stabbed twenty-seven times on the street outside her Guatemala City office in September 1990. Her death was attributed to common crime - a robbery gone wrong - despite the extreme and unnecessary violence, the political context surrounding her death, and the fact that her wallet was not taken. Indeed, the first police investigator to suggest an alternate hypothesis - one hinging on political motives - was himself killed. For an outstanding report on this case, see Lawyers Committee for Human Rights, A Test of Justice in Guatemala: The Myrna Mack Murder Trial (2003), available at www.humanrightsfirst.org/defenders/ hrd-guatemala/hrd-mack/test-of-justice.pdf.
5. Guatemala's Lethal Legacy, supra note 1.
6. I b i d.
7. I b i d.
8. I b i d.
9. Mary Jo McConahay, A Nun's Story: From Reconciliation to Murder in Guatemala, Pacific News Service, 8 May 2001, available at www.pacificnews.org/content/pns/2001/may/0508anun.html (hereinafter A Nun's Story).
10. Asesinato de monja podría ser político, BBC Mundo, 8 May 2001, available at www.news.bbc.co.uk/hi/spanish/news/ newsid_1318000/1318707.stm.
11. See also Margaret Swedish, Who Killed Sr. Barbara Ford?, Religious Task Force on Central America and Mexico, Central America/ Mexico Report, Vol. 21 No. 3 (July 2001), available at www.rtfcam.org/report/volume_21/No_3/article_2.htm.
12. A Nun's Story, supra note 8.
13. Suspect Arrested in Fatal Shooting of Nun in Guatemala, Catholic World News, 30 Jul 2001, available at www.cwnews.com/news/ viewstory.cfm?recnum=16087.
14. Furthermore, evidence suggests that death squads organized by government security forces have, in the past, deliberately targeted individuals who were not particularly well-known. In a secret (though subsequently declassified) US Department of State cable from 1991, then-US Ambassador to Guatemala Thomas Stroock, describes the strategy and tactics behind a series of such attacks. It reads, in part, In each case, the victim was not particularly well-known outside of his or her circle of immediate associates; the victims were not persons generally considered important or influential in society at large... why were they selected? That the victims are generally unknown in wider society means a more muted reaction both locally and abroad; it makes the question "why?" more difficult to answer and many non-political explanations, e.g. common crime, can plausibly be put forward to explain the victimization of a relatively anonymous person. While the victims are not figures of wide renown, they are well known within the small groups comprising the left. The bolt-from-the-blue strike against one of their members causes a ripple of terror to go through those groups ("He wasn't even the most important one in our group; if they are willing to get him, nobody is safe"). Cable from Thomas Stroock, Ambassador, ¶¶ 4-5 (1991), available at www2.gwu.edu/~nsarchiv/NSAEBB/NSAEBB111 /doc04.pdf. The documented use of such a strategy should encourage us to question the wisdom of assuming that the political prominence of the victim is a meaningful way to determine whether a given crime was, or was not, politically motivated.
15. Mano dura is a commonly-used term in Latin America; although the term literally translates to "hard-handedness" and is often interpreted as "rule by an iron fist." However, no true equivalent exists in English.
16. The UN-sponsored truth commission in Guatemala, officially called the Historical Clarification Commission and often referred to as the CEH by the acronym of its Spanish name, concluded in 1999 that 93 percent of the abuses were committed by agents of the Guatemalan state-either the army or its paramilitary adjuncts. See CEH: Memoria del Silencio Guatemala 24-25 (1999), available at shr.aaas.org/guatemala/ceh/ report/english/recs4.html [hereinafter CEH: Memory of Silence].
17. See Jennifer G. Schirmer, The Guatemalan Military Project: A Violence Called Democracy (1998).
18. CEH: Memory of Silence, supra note 14, at 43.
19. I b i d. at 48-49.
20. Guatemala's Lethal Legacy, supra note 1 .
21. I b i d.
22. In the 9 November election he received the most votes, ironically, in the very same departments where under his leadership the war exacted its most brutal toll (El Quiche, and also Huehuetenango). See Jennyffer Paredes and Julieta Sandoval, Berger Supera a Colom con el 9.92 por ciento, Prensa Libre, 11 November 2003, available at www.prensalibre.com/pl/2003/noviembre/11/73203.html.
23. See Martha Huggins, Political Policing: The United States and Latin America (1998);
24. Paul Chevigny, Edge of the Knife: Police Violence in the Americas (1995);
25. Paul Chevigny, The Populism of Fear: Politics of Crime in the Americas, 5 Punishment & Society 77 (2003).
26. Steven Hendrix, Guatemalan "Justice Centers": The Centerpiece for Advancing Transparency, Efficiency, Due Process, and Access to Justice , 15 Am. Univ. Int'l L. Rev. 813, 865-66 (2000).
27. Guatemala's Lethal Legacy, supra note 1.
28. Comité Pro Justicia y Paz, Situación de los Derechos Humanos en Guatemala, October 1988, cited in Historical Clarification Commission, Vol. 1, Ch. 2, ¶ 468 (1999) [hereinafter CEH] (on file with author).
29. Oficina de Derechos Humanos del Arzobispado de Guatemala, Guatemala Nunca Mas Vol. II: Los Mecanismos del Horror, 165 (1998) (on file with author) (hereinafter Guatemala Nunca Más). The Oficina de Derechos Humanos del Arzobispado de Guatemala had the Guatemala Nunca Más printed in 1998. The complete report covers 5,000 testimonies in four volumes. Volume 1, "Impactos de la Violencia," examines the consequences of the violence for individuals, families, women, children, and communities. Volume II, "Los Mecanismos del Horror," analyses the massacres, the structure and policies of the military, and the role of torture. Volume III, "El Etorno Histórico," covers the historical antecedents, especially in the 1944-54 period, and the role of the Church as protagonist. Volume IV, "Victimas del Conflicto," organizes the data of the period by categories: victims of the massacres by community, the disappeared, and the tortured.
30. CEH, supra note 24, ¶ ¶ 244-45.
31. I b i d. ¶ 258.
32. I b i d. ¶ 259.
33. I b i d. ¶ 261.
34. Victoria Sanford, Buried Secrets: Truth and Human Rights in Guatemala (2003).
35. See also Linda Green, Fear as a Way of Life: Mayan Widows in Rural Guatemala (1999);
36. Jennifer G. Schirmer, The Guatemalan Military Project: A Violence Called Democracy (1998);
37. Rigoberta Menchú, Me llamo Rigoberta Menchú y así me nació la conciencia (Elisabeth Burgos ed., 1983);
38. Susanne Jonas, The Battle for Guatemala: Rebels, Death Squads, and U.S. Power (1991);
39. Susanne Jonas, Of Centaurs and Doves: Guatemala's Peace Process (2000);
40. CEH, supra note 24;
41. Guatemala Nunca Más, supra note 25, Vol. III: Victimas Del Conflicto (on file with author); Guatemala Nunca Más, Victimas Del Conflicto (on file with author)
42. Robert Carmack, Harvest of Violence (1988);
43. Ricardo Falla, Masacres de la Selva [Masacres in the Jungle]: Ixcán, Guatemala, 1975-1982 (1992).
44. Mayra Buvinic, Andrew Morrison, & Michael Shifter, Violence in Latin America and the Caribbean: A Framework for Action (Inter-American Development Bank, Mar. 1999), available at www.iadb.org/sds/doc/ 1073eng.pdf.
45. Alejandro Gaviria & Carmen Pages, IDB Working Paper #408, Patterns of Crime Victimization in Latin America (Inter-American Development Bank, Oct. 1999), available at www.iadb.org/res /publications/ pubfiles/pubWP-408.pdf;
46. Juan Luis Londono & Rodrigo Guerrero, Violencia en América Latina: Epidemiología y Costos (Inter-American Development Bank, Aug. 1999), available at www.iadb.org/res/publications /pubfiles/ pubR-375.pdf.
47. Robert L. Ayres, Crime and Violence as Development Issues in Latin America and the Caribbean 3 (1998), available at www-wds.worldbank.org/servlet/WDSContentServer/WDSP/IB/1998/01/01/ 000009265_3980429110659/Rendered/PDF/multi¶ge.pdf.
48. In Guatemala, official government statistics are largely unavailable and problems in the system of data collection call into question the reliability of those numbers that can be obtained, yet even the Guatemalan National Institute of Statistics' figures on violent deaths suggest a 1996 rate of 58.68 per 100,000. National Center of Economic Investigations (CIEN), Diagnóstico de la Violencia en Guatemala 2 (1999) (on file with author).
49. This figure, while significantly below most estimates by international sources, nonetheless places Guatemala's homicide rate at an alarmingly high level. For more on crime in postwar Guatemala, see Caroline Moser & Cathy McIlwaine, Violence in a Post-Conflict Context: Urban Poor Perceptions from Guatemala (2001), available at www-wds.worldbank.org/servlet/WDSContentServer/WDSP/IB/2001/12/11/ 000094946_01112104010285/Rendered/PDF/multi0page.pdf.
50. Cited in Luis Pásara, La Justicia en Guatemala, 2 Diálogo 3 (Mar. 1998) (on file with author). Diálogo is part of a regular publication put out by La Facultad Latinoamericana de Ciencias Sociales (FLACSO) in Guatemala.
51. I b i d.
52. Lorena Seijo, 86% de la población cree que la justicia es corrupta , Prensa Libre, 18 Mar. 2003, available at www.prensalibre.com/ pl/2003/Marzo/18/51743.html.
53. Ana Arana, The New Battle for Central America, 80 For. Aff. 89-90 (Nov./Dec. 2001).
54. I b i d.
55. I b i d.
56. Interview with Vinicio Cerezo Arévalo, former president of the Republic of Guatemala, in Guatemala City (12 July 1999).
57. Interview with Ricardo Ardón, Executive Director of CACIF, in Guatemala City (17 June 1999).
58. Interview with ladina woman from Guatemala City, in Guatemala City (2 July 1999).
59. Interview with Mayan woman from rural El Quiche (26 Oct. 2000).
60. Interview with K'iche Mayan woman from rural El Quiché (26 Oct. 2000).
61. Interview with second K'iche Mayan woman from rural El Quiché (26 Oct. 2000).
62. Not literally: in fact, the Palace is now a museum, and no longer houses the President's offices.
63. Tim Rogers, The Spiral of Violence in Central America, Zmag, Sept. 2000, available at www.thirdworldtraveler.com/Central_America/ Spiral_Violence_CA.html.
64. See Report of the Special Rapporteur on the Independence of Judges and Lawyers, Dato' Param Cumaraswamy, submitted in accordance with C.H.R. Res. 1999/31, Addendum, U.N. ESCOR, Comm'n on Hum. Rts., Report on the mission to Guatemala, U.N. Doc. E/CN.4/2000/61/Add.1 (2000);
65. Report of the Special Rapporteur on the independence of judges and lawyers, Dato' Param Cumaraswamy, submitted in accordance with C.H.R. Res. 2001/39, Addendum, U.N. ESCOR, Comm'n on Hum. Rts., Report on the mission to Guatemala, U.N. Doc. E/CN.4/2002/72/Add.2 (2001).
66. See Susan Peacock and Adriana Beltran, Hidden Powers in Post-Conflict Guatemala: Illegal Armed Groups and the Forces Behind Them 69-75 (Washington Office on Latin America, 2003).
67. Guatemala: Fear for Safety/Threats, Amnesty International UA 43/03, AMR 34/006/2003, 12 Feb. 2003, available at web.amnesty.org/library/ index/ENGAMR340062003?open&of=ENG-2m2.
68. See A Country Turns Upside Down, The Economist, 15 May 2003, at 56.
69. Alfredo Moreno Molina, a former military intelligence officer and leader of an extensive smuggling ring with links to the Cali cartel and the deputy defense minister among its associates, was among those exposed in a 1996 anti-corruption operation. Arana, supra note 37. Moreno was convicted along with some of his accomplices, although many implicated in these investigations walked free. One of them was Jacobo Salan Sánchez, who was subsequently appointed to head the notorious Presidential Guard (EMP) in 2000; shortly after his appointment, investigations by the Guatemalan daily El Periódico revealed that he was running death squads from his office, and he resigned. Reporters involved in breaking the story received death threats. At the time of this writing, Salan was among the men under investigation in the inquiries publicly announced by Attorney General of Leon in 2002.
70. See Steve Kettmann, Guatemala Fails to Pass U.S. Antinarcotics Test, S. F. Chron., 1 Feb. 2003, at A11.
71. See Tim Johnson, Guatemalan Seeks Global Help to Lower Crime in Weary Land, Miami Herald, 9 Feb. 2003, at 5A, available at www.southernborder.berkeley.edu/spring2003/list_articles/ 0209-miamiherald-guatemalancrime.htm.
72. In Serbia, Whitmore explains, Milosevic had relied heavily on paramilitary structures with shadowy ties to trafficking (in heroin and humans) to carry out ethnic cleansing campaigns in Croatia, Bosnia, and Kosovo. Yet when reformer Zoran Djindijic promised key leaders of these criminal forces jobs in the new government with international backing, postponing calls to purge the security forces and turning a blind eye to their ongoing operations, a marriage of convenience emerged. Djindjic, darling of the West, was able to oust Milosevic with a little help from these dark forces he had previously commanded. Yet the arrest of Milosevic in April 2001, and the resultant inquiries from the Hague, put strains on this relationship. Under international pressure, Djindjic decided to cooperate with the tribunal and moved to prosecute the underworld leaders with links to the country's bloody past. In January 2003, an open letter to Serbian newspapers from notorious Milorad Lukovic warned Djindjic that his days were numbered, threatening retaliation for his "unpatriotic" collaboration with Western human rights inquiries. In February, an attempt was made on his life by a gangster nicknamed "Bugsy," with ties to Lukovic's network; in March, he was felled by a sniper's bullet. In Iraq, a similar dynamic may be at work. in the early days of the US and British invasion of Iraq in 2002, accounts of the horrific tyranny of Saddam Hussein's regime poured Westward. Eager to promote its intervention as the dawn of a democracy, Washington celebrated the Iraqi spirit in rejecting Saddam's Baath party, and images of celebratory crowds toppling statues seemed to second that message. Yet months later, signs of a different story emerged. The ruthless paramilitary units that terrorized Iraqi dissidents for so many years, some of them headed by members of Saddam's immediate family, did not disappear with the invasion. Indeed, the sophistication of some recent ttacks on targets associated with the occupying forces, such as the 19 August bombing of the UN compound, bear the hallmarks of Baath party involvement. Rampant looting nd violence have struck newfound fears into the hearts of many Iraqis, as Amnesty International reported in its earliest post-invasion dispatches documenting the clamor for basic security. See Amnesty International, MDE 14/143/2003, Iraq: The Need for Security (2003), available at web.amnesty.org/library/index/ENGMDE141432003. In this climate, forces tied to the past may be finding new sympathizers, "not because locals are Saddam sympathizers, but because they long for the security and economic stability of the old regime." Maureen Fan & Drew Brown, U.S. Appears to be Losing Battle for Hearts, Minds of many Iraqis, Seattle Times, 13 Nov. 2003, at A3, available at www.commondreams.org/headlines03/1113-05.htm.
73. Brian Whitmore, Letter from Belgrade, The Nation, 5 May 2003, at 21-22.
74. Ardón Interview, supra note 41. The then-Executive Director of the country's leading private business, agriculture, and industrial group, CACIF, 1999, provided an example of the tidy logic which separates crime from social concerns. He told me that poverty contributed to crime, but was not its main cause. "I want to emphasize this, and for one simple reason," he explained. "if I bought the argument that poverty was the cause of crime, I would be immediately accepting that the poor people of my country are criminal people, and that simply isn't true." He went on to explain that criminals were not poor citizens lacking opportunities for legitimate employment, but antisocial opportunists who require stricter control; deterrence, therefore, is about the application of negative sanctions rather than the provision of positive opportunities.
75. See, for example, the arguments against human rights cited in Frank La Rue, Harvey Taylor, and Christian Salazar-Volkmann, Can Human Rights Be Denied to Children?: Opposition and Defense of the Code for Children and Youth in Guatemala, 31 (Center for Human Rights Legal Action (CALDH) 1998) (on file with author).
76. Angelina Godoy, Lynchings and the Democratization of Terror in Postwar Guatemala, 25 Hum. Rts. Q. 640, 643-44 (2002).
77. Víctor Ferrigno, El Estado Democrático de Derecho Frente al Conflicto Social, a paper presented at the Conference Linchamientos: Diagnóstico y Búsqueda de Soluciones, held in Panajachel, Guatemala, May 1998 (on file with author).
78. In Guatemala, for example, the 1986 Constitution provides for capital punishment in certain cases of aggravated homicide, such as those where the victim is extremely young or old, or in cases where murder is committed as part of a kidnapping, but recent legislation has moved to extend the use of the death penalty to a broader range of crimes, especially kidnappings of all sorts-even those that do not result in death. As a signatory of the "Pacto de San José" (American Convention on Human Rights), however, Guatemala is precluded from expanding the use of the death penalty to crimes for which it was not previously contemplated. Guatemala's new death penalty legislation, therefore, directly contravenes its responsibilities under international law, and even violates Article 46 of the Guatemalan Constitution, which recognizes the preeminence of international humanitarian law and human rights treaties. This contradiction has created confusion, with some judges recognizing the primacy of national legislation, and therefore dictating capital sentences in such cases, while others refused to do so, complying instead with international norms (and the provisions of Article 46).
79. This term is Paul Chevigny's. See Chevigny, The Populism of Fear, supra note 21.
80. A. Douglas Kincaid, Demilitarization and Security in El Salvador and Guatemala: Convergence of Success and Crisis, in Globalization on the Ground: Postbelium Guatemalan Democracy and Development 101-18 (Christopher Chase-Dunn, Susanne Jonas, & Nelson Amaro eds., 2001).
81. This characterization is deeply ironic given that much of the party's leadership, including its Maximum Leader, General Efraín Ríos Montt, are well-known war criminals. Furthermore, the current President of the Republic, FRG member Alfonso Portillo, has confessed to killing two men in Mexico in 1982, and then fleeing the country to escape trial. When this would-be scandal broke during the 1999 campaign, he admitted everything: claiming self-defense, he alleged that he could never have obtained a fair trial in Mexico, and was forced therefore to evade the law and leave the country. Incredibly, Portillo was able to take advantage of his criminal record in radio advertisements that proudly proclaimed "Portillo: If he can defend himself, he can defend you and your family." The fact that this episode turned out to be a political boon rather than a liability speaks to the high tolerance for violence and the enduring appeal of strongmen, even those who break the law, as political leaders in Guatemala-and calls into question the meaning of "law and order" platforms put forward by the FRG.
82. Not enough police, but who wants the army back in charge again?, The Economist, 29 July 2004, available at www.economist.com/world/ la/displayStory.cfm?story_id=2968778.
83. President Berger's approach to citizen security has yet to be clearly defined, but early indications, such as the continuation of joint army-police patrols, suggests a continuation of past policies. See Ejercito y Policia Iniciaron Patrullajes Conjuntos, Prensa Libre 20 Jan. 2004 (on file with author).
84. I b i d.
85. Interview with Ladino man, in Guatemala City (28 June 1999).
86. Interview with Four Ladino men, in Guatemala City (24 June 1999).
87. The term "the human rights" is often used to refer to the people who promote human rights, as well as the concept itself, see James Holston & Teresa P. R. Caldeira, Democracy, Law, and Violence: Disjunctions of Brazilian Citizenship, in Fault Lines of Democracy in Post-Transition Latin America (Felipe Agüero & Jeffrey Stark eds., 1998), note that this is the case in Brazil as well. As a foreigner in Guatemala, where foreigners are often associated with human rights work, I have been asked, "Are you one of the human rights?"
88. This is perhaps even true, if one considers that most mechanisms by which crime has historically been combated in Guatemala fall outside the bounds of acceptable law enforcement under human rights standards: true adherence to a human rights regime does imply a fundamental shift in crime control tactics.
89. See, e.g., Priscilla B. Hayner, Unspeakable Truths: Confronting State Terror and Atrocity (2001);
90. Ruti G. Teitel, Transitional Justice (2000);
91. Impunity and Human Rights in International Law and Practice (Naomi Roht-Arriaza ed., 1995);
92. Martha Minow, Between Vengeance and Forgiveness: Facing History After Genocide and Mass Violence (1998);
93. Transitional Justice and the Rule of Law in New Democracies (James McAdams ed., 1997).
94. Mons. Gerardi, Head of the Catholic Church's Human Rights Office, was bludgeoned to death in April 1998 two days after he presided over the release of the Church's human rights report Guatemala Nunca Más, supra note 30.
95. Despite the obvious political overtones in his killing, prosecutors initially posited that he had been slain by his own dog (despite its advanced age and physical inability to inflict such grievous wounds). It was later suggested that the Bishop's death was the result of a homosexual love triangle, or the outcome of his having "known too much" about criminal gangs trafficking in stolen religious artifacts for sale on the black market. Despite these allegations, in a landmark victory for human rights, in 2001 the courts found three military men guilty of extrajudicial execution in connection with the killing; appeals to that sentence were pending at the time of this writing. (For a detailed account of the Gerardi case, see Robert F. Kennedy Memorial Center for Human Rights, The Investigation of the Murder of Guatemalan Bishop Juan Gerardi: A One-Year Update (1999), available at www.rfkmemorial.org/CENTER/gerardi.htm;
96. see also Guatemala's Lethal Legacy, supra note 1.)
97. For more on Myrna Mack, see A Test of Justice in Guatemala: The Myrna Mack Murder Trial, supra note 3.
98. Religious Task Force on Central America and Mexico, Central America and Mexico Report, Vol. 21 No. 3 (2001).
99. Steven Hendrix, Lessons from Guatemala: Renewing US Foreign Policy on the Rule of Law, 13 Harvard Int'l Rev. 4, 14-18 (2002), available at hir.harvard.edu/articies/?id=948.
100. There are exceptions to this rule, of course. Tribunals convened to respond to individual human rights crises, including those at Nuremberg, have tried individuals, and the International Criminal Court is also capable of charging individuals.
101. Margaret Keck & Kathryn Sikkink, Activists Beyond Borders: Advocacy Networks in International Politics (1998).
102. For a thought-provoking critique along these lines of the human rights movement's work on violence against women, see Catharine MacKinnon, Crimes of War, Crimes of Peace, in On Human Rights: The Oxford Amnesty Lectures 1993, at 83 (Stephen Shute & Susan Hurley eds., 1993).
103. See Amnesty International, amr 41/027/2003, Intolerable Killings: Ten Years of Abductions and Murders of Women in Ciudad Juarez and Chihuahua (2003), available at web.amnesty.org/library/indey/ ENGAMR410272003.
104. See Claire Marshall, Murderers Prey on Guatemalan Women, BBC News World Ed., 6 Dec. 2003, available at news.bbc.co.uk/2/hi/ americas/3294659.stm.
105. For an illuminating discussion of this perception among Colombians, see Luis Alberto Restrepo, The Equivocal Dimensions of Human Rights in Colombia, in Violence in Colombia 1990-2000: Waging War and Negotiating Peace 97 (Charles Bergquist et al. eds., 2001).
106. For some discussion of similar trends in Brazil, see Teresa P.R. Caldeira, City of Walls: Crime, Segregation, and Citizenship in Sao Paulo (2000).