In the nearly twenty years since 1994, the international community and the Rwandan government have pushed to hold individual perpetrators accountable for the genocide. Judicialization has occurred at multiple levels. Over ninety persons-those deemed most responsible-have been indicted by the International Criminal Tribunal for Rwanda (ICTR), an ad hoc institution established by the U.N. Security Council in November 1994. Approximately ten thousand individuals have been prosecuted in specialized chambers of national courts in Rwanda. According to the Rwandan government, nearly two million people have faced neo-traditional gacaca proceedings conducted by elected lay judges throughout the country. Gacaca proceedings concluded in 2012. A handful of Rwandan defendants have been prosecuted by foreign national courts, including through assertions of universal jurisdiction. On June 24, 2011, ICTR Trial Chamber II convicted Pauline Nyiramasuhuko, formerly Rwanda's Minister of Family and Women's Development, of conspiracy to commit genocide and of genocide; of the crimes against humanity of extermination, rape, and persecution; and of the war crimes of violence to life and outrages upon personal dignity. She was sentenced to the harshest punishment possible, namely, life imprisonment. At the time of her conviction, she was sixty-five years old. Although much of the literature on gender and conflict focuses, appropriately, on women as victims of violence, women also act as agents of violence, including mass atrocity, during conflict situations. The Nyiramasuhuko case offers an opportunity to more carefully examine this textured, and largely underappreciated, aspect of the metastasis of atrocity. This is the central preoccupation of this Article.
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