On February 20, 2014, the Court of Appeals of Port-au-Prince ruled [3] (unofficial English translation) that former dictator Jean-Claude Duvalier could be charged with crimes against humanity, reversing a 2012 lower court decision that Duvalier could not be charged because the statute of limitations on such crimes had run out.  The Court of Appeals also stated that “there are serious indicia relating to the indirect participation and the criminal responsibility of the accused, Jean-Claude Duvalier, for failing to take all necessary and reasonable measures to prevent the commission of crimes and punish the perpetrators.”  According to a news report [4], the case has been brought by alleged victims of forced disappearances and torture during Duvalier’s rule.  Duvalier fled into exile in 1986 and denies any responsibility for abuses during his fifteen-year rule.