Gambian Torture Prosecuted in the U.S.

It's easy to see why the trial of former Gambian death squad leader Michael Sang Correa is historic. But before I get into that, let's stop and talk about why it matters to women's rights.

Correa was found guilty by a federal court in Denver on April 15, 2025, of having committed torture of Gambian citizens in Gambia. He was caught in the U.S. after he overstayed his visa.

This is significant for women's rights because femicide, occurring around the world, often involves torture. Torturing women is a favorite tool of the gangs that run the Golden Triangle (El Salvador, Guatemala, and Honduras). Plus, courts - including the U.S. Board of Immigration Appeals and the Internationnal Criminal Tribunal for the Former Yugoslavia - have found that rape is torture.

My question is: Will women's rights attorneys in the United States start using the Torture Act - which has only been used three times in the 29 years since its enactment - to seek redress for women who have suffered from violence? I think that the door has been cracked ever-so-slightly - and we should shove our foot in before it closes. U.S. courts are not friendly to extraterritorial jurisdiction. Just ask the Alien Tort Claims Act.

As to Correa, he was a member of the death squad the "Junglers" (I almost hate to put quotation marks around it, lending the group a certain credibility), who tortured suspected resistance members against then-president Yahya Jammeh. Ultimately, the federal court, via its jury of ordinary American heros (jury members) found Correa guilty of both torture and conspiracy to commit torture. Extraordinary Gambian heros (torture victims and testifying witnesses) flew in from The Gambia for the trial.

Importantly, two other members of the Junglers have been brought to justice in Germany and Switzerland. As an aspirational international human rights lawyer, and a U.S. women's rights lawyer, I always find the extrateritorial applicaiton of jurisdiction against human rights violators fascinating and hopeful. NON-NERD EDIT: "Extraterritorial applicaiton of jurisdiction" happens when a court in Country 1 prosecutes or litigates against a defendant that is not a resident of Country 1 for acts that the defendant did NOT commit in Country 1. It is rare, and even rarer in the United States.

I do not know of any other laws whereby the United States prosecutes non-Americans (except maybe the Convention Against Torture) for torture that was committed outside of the United States, but I will most certainly be on the lookout.