From: Slye, Ron
Sent: Fri 3/18/2005 2:42 PM
To: robertjamieson@seattlepi.com
Subject: Corries Suit against Caterpillar

Dear Robert,

I read with great interest your article about the lawsuit the Corrie family has brought against Caterpillar Inc.  I have read your columns with great admiration over the years, and have enjoyed chatting with you the few times we have met (I think the last time was at an event for the Desmond Tutu Peace Foundation -- maybe when Linda Biehl came to speak?)

I should disclose at the outset that not only is the human rights clinic here at the Seattle University School of Law representing the Corries in this case, but that I have been helping our clinic, our students, and the other lawyers working on the case.  So I cannot claim to be completely objective about the case.  Having said that, my expertise is in the area of public international law and international human rights law.  There are three points I would therefore like to make concerning your comments on the case.

First, holding individuals, including corporations, accountable for their involvement in violations of human rights law is not a new idea.  Most prominently corporations and corporate officers were held accountable after World War II for their complicity in the Nazi holocaust.  Today, lawsuits have proceeded against, among others, Shell Oil Company and Unocal for their complicity in human rights abuses in Nigeria and Myanmar respectively.  Domestically corporations have always been held accountable for some harms caused by their products . The defense that we were just selling the materials and did not pull the trigger (or in this case drive the bulldozer) is not a recognized defense under both domestic and international law, if it ever was.  It is reminiscent of the "just following orders" defense that has been so thoroughly discredited since World War II.  For a more contemporary analogy, think of the individuals and organizations who finance terrorism -- for example the attacks on September 11, 2001.  Those individuals and organizations did not fly the planes; they did not train the pilots; they did not plan the attacks -- but they provided financing and other support knowing that some sort of terrorist attack was to happen.  It is clear under both US and international law that such individuals and organizations can be held accountable for those acts.  Imagine a corporation that sold airplanes to the September 11th attackers knowing that they would be used for such a purpose -- such a corporation would clearly be partially liable for those attacks, assuming one could show that they had knowledge of the use to which their airplanes would be put.

Second, the theory of this case is not your product was used in a way that hurt someone.  It is that you provided a product to someone that you knew was using that product to harm others; that you worked with that customer to alter your product to make it better suited for harming others; and that you continued to provide such assistance even after it was brought to your attention that your products were used to commit such harm.  A similar case has just been brought against a Dutch chemical manufacturer who provided chemicals to Saddam Hussein's Iraq that were then used to murder innocent Iraqis in Halabja.  His defense was that while he provided the chemicals he did not know what they would be used for.  While one might hesitate at holding someone accountable for acts they did not anticipate or could not foresee (although I can think of some good arguments why one might still hold such an individual accountable for such sales), the claim by the Corries is that Caterpillar knew that their specially designed armored bulldozers were being used to harm innocent civilians in violation of the laws of armed conflict and international human rights law.  (On the Dutch prosecution, see the following BBC story: 
http://news.bbc.co.uk/1/hi/world/middle_east/4360137.stm 

Finally, you say that the Corries should sue the state of Israel .  As a political and moral matter I agree with you.  Unfortunately the law does not.  It is a sad reality of US law that there are only a narrow number of circumstances that allow a suit to be brought against a foreign sovereign state.  None of those circumstances exist here.  So the Corries and others should exert political and moral pressure on the Israeli government, but they cannot exert legal pressure against them.  They can bring legal actions against others who were involved in the death of Rachel and other innocent civilians in the occupied territories.  That is what they are doing.  If as a result of this lawsuit corporations like Caterpillar stop providing their products to individuals who they know use them to harm other people, that would be a great victory.  If I lend you my car, knowing that you plan to use it to hit someone against whom you have some dispute, I can be held liable as an accomplice in the harm you created.  That is the simple principle the Corries would like to apply here.

I would be happy to discuss this further with you, either by e-mail, phone, or in person.

Thanks again for being a responsible and engaged public citizen through your column and the other work that you do, and for taking the time to read this e-mail.

All the best,

Ron

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Ronald C. Slye
Associate Professor
Director, International and Comparative Law Programs
Seattle University School of Law
901 12th Avenue , Sullivan Hall
P.O. Box 222000
Seattle , WA   98122-1090