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Justice after Transition: On the Choices Successor Elites Make in Dealing with the Past
Author(s): Luc Huyse
Source: Law & Social Inquiry, Vol. 20, No. 1 (Winter, 1995), pp. 51-78
Published by: Wiley on behalf of the American Bar Foundation
Stable URL: http://www.jstor.org/stable/828857 .
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massivecriminalprosecutionof the supportersof the previousorderto unconditionallyclosing the book. All policy choices involve answersto two
key questions:whether to rememberor forget the abuses-the issue of acknowledgment-and whether to impose sanctionson the individualswho
are co-responsiblefor these abuses-the issue of accountability.2
By farthe most radicalinterpretationof acknowledgmentand accountof the perpetrators.
ability is to be found in the outrightcriminalprosecution
This has been the officialpolicy towardcollaboratorsin all West European
countrieswhich duringWorld War II were occupied by the Germans.A
recent example is Ethiopiawhere some 3,000 officialsof the fallen Mengistu regimehave been namedfor trial.By contrast,as a strategyfor dealing
with the past, criminalprosecutionhas encounteredalmost no supportin
regimes
post-1989Easternand CentralEuropeand in the post-authoritarian
of Latin America.
Lustrationor disqualificationof the formerelites, of the agents of the
secret police and their informers,or of civil servantsis a second way to
addressthe questions of acknowledgmentand accountability.Sometimes
disqualification,includingthe loss of political and civil rights,accompanies
a criminal conviction, as occurredin postwarBelgium, France, and The
Netherlands.In other instances,as in most of the postcommunistcountries
of East and Central Europe,lustrationis a way to sidestepcriminal prosecution.
The grantingof unconditionalamnestyto those who committedpolitically based crimesis at the other end of the spectrum.3In some instances
the unrestrictedpardonis the resultof the self-amnestythat the outgoing
elites unilaterallyawardthemselvesbeforethe transitiongets underway.In
other instances,impunityis the outcome of negotiationsbetween old and
new leaders.In Uruguay,for instance, the governmentthat succeededthe
militarydictatorshipenacted,underpressurefrom the military,an amnesty
law (1986). Post-FrancoSpain is an exampleof a thirdroute towardimpunity: almost all democraticforcesagreedto confer immunityto individuals
who committedcrimesdefendingor opposingthe Francoregime.
Amnesty, but not amnesia, is the substanceof a fourth strategy.Its
The firstgoal of such a commissionis
usualformatis the TruthCommission.
2. The distinctionbetween acknowledgmentand accountabilitywas made at the Salzburgmeeting(7-10 March1992) of the Charter77 Foundation'sProjecton Justicein Times
of Transition.For moreon the Projecton Justicesee note 9.
3. Amnesty, grantedby the executive or the legislature,removesthe punishabilityof
certainacts;amnestythus abrogatescrimeand punishment;it can be usedto forecloseprosecutionsbut also to cancel the sanctionsalreadyimposed.Pardonis, accordingto Black'sLaw
Dictionary,an "executiveaction that mitigatesor sets aside punishmentfor a crime."The
dictionaryadds:"The distinctionbetween amnestyand pardonis one ratherof philological
interestthan of legal importance."Impunity(or immunity)is a de facto situationthat is the
resultof amnestyor pardon.I use here the terms"amnesty,""pardon,"
"impunity,"and "immunity"as synonyms.
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(in part I) the prosand cons of each of the availablepolicy options. I then
move to a comparativedescription(in part II) of the course justice after
transitiontook in two groupsof countries:(a) Belgium,France,and The
Netherlandsat the end of WorldWar II and (b) postcommunistCzechoslovakia, Hungary,and Poland.8Part III deals with the specificfactorsthese
new elites take into consideration.I also assessthere three potential causes
of policy. The first is the legacy of the past. Authoritarianor totalitarian
regimesdifferin many aspects,for example,in their scope and the crimes'
natureand duration.The second is the internationalcontext at the time of
the transition,that is, the absenceor presenceof supranationallegal norms
on human rights and of institutionsto implementsuch norms.The last is
the mode of transitionand its ensuingimpacton the balanceof powerbetween the old and the new order.This list of causes is derived from the
literatureon regimetransitionsand from the pool of experiencesdiscussed
at variousmeetingsand conferences.9In my conclusionI supportthe proposition that there are no miraclesolutions to the question of how to deal
with a repressivepast.
I.
in SouthAfrica(CapeTown:IDASA,1994)("Boraine,
of
is a veryusefulsummary
Dealing"),
thepoliticalandacademic
ThirdWave211-32(citedin note 1).
debate.SeealsoHuntington,
Those who emphasizethe beneficialeffects of prosecutionbring forwardtwo crucialreasons.First,punishingthe perpetratorsof the old regime
advancesthe cause of buildingor reconstructinga morallyjust order.The
second reasonhas to do with establishingand upholdingthe youngdemocracy that succeedsthe authoritariansystem.
1. Puttingbackin place the moralorderthat has brokendown requires
that "justicebe done,"the proponentsof prosecutionsargue.They believe
that the successorgovernmentowes it, firstof all, as a moralobligationto
the victimsof the repressivesystem.Post-authoritarian
justiceservesto heal
the wounds and to repairthe private and public damagethe antecedent
regimeprovoked."It also, as a sortof ritualcleansingprocess,pavesthe way
for a moral and political renaissance.'2Abolishing the monumentsof the
past (the statues of the Lenins and the Stalins) is one way to cleanse a
society;evicting those who are held responsiblefor yesterday'scrimesis another. A countryin which such cleansingremainsunfinishedwill, it is said,
be plagued by continuous brooding and pondering. Asked by Adam
Michnik,a leaderof the Polishoppositionto communistrule and co-editor
of the Warsawdaily newspaperGazeta,what he thought of lustration,the
GermanwriterJirgen Fuchsanswered:"Ifwe do not solve this problemin a
definiteway, it will haunt us as Nazismdid. We did not denazifyourselves,
and this weighed on us for years."'3The French historian Henri Rousso
labels the case of postwarFrance,where the "collaborationd'Etat"was not
fully tried, as a never ending neurosis.14
2. A secondargumentin favorof a judicialoperationagainstthe advocates of the old regimeis that it strenghtensfragiledemocracies.
11. Accordingto Huntington,ThirdWave213, this is one of the main argumentsof
those in favor of prosecution.See also Aryeh Neier, formerexecutive directorof Human
RightsWatch: "As a civilisedsociety we must recognisethe worthand dignityof those victimizedby abusesof the past."Cited in Boraine,Dealing3 ("Neier,in Dealing").
12. That is exactlywhat the termlustration,
accordingto TheOxfordConciseDictionary,
evokes:"purificationby expiatorysacrifice,ceremonialwashing."
13. Fuchs,cited by Adam Michnik, "Justiceor Revenge?"4 J. Democracy20, 25 (Jan.
1993).
de Vichyde 1944 a nosjours(Paris:Seuil, 1990) ("Rousso,
14. HenriRousso,Le syndrome
The uneasinesswasrevivedwhen in June 1993 Rent Bousquet,the FrenchsecreSyndrome").
tarygeneralof police underthe Vichy regime,was murderedby a psychotic.Manyfelt that
the killing of Bousquet,whose expected trial might at last have broughtthe wartimestate
beforethe courts,was"justicedenied."Rumorsof the reluctanceat the highestlevel to effectively put the Vichy regime on trial were amplified.See "LedossierBousquet,"Liberation
(Special Issue), 13 July 1993, at 1-52.
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In the first months after the transition,it is said, the survivalof the
successorregimedependson swift and firmaction againstpro-authoritarian
officialsand their following.Such action is seen as a necessaryprotection
Moreover,if the prosecutionissueremains
againstsabotage"fromwithin.""5
and
other
forms
of
social
untouched,
politicaldisturbancemaybe triggered,
with perhapsa risk of vigilantejustice with summaryexecutions,or unbridled screeningof political personnel,journalists,and judges may be instigated as happened in Czechoslovakia in 1991 and in Poland more
recently.16It mayalso give birth to conspiracytheoriesin which the leaders
of the successorregimearelabeledas the hiddenagentsof the old orderthat
they are treatingin a too soft and ambiguousway.
What a new or reinstateddemocracyneeds most, however, is legitimacy. Prosecution,Huntington writes, is seen as "necessaryto assert the
supremacyof democraticvalues and normsand to encouragethe public to
believe in them."17Failureto prosecuteand lustrate,conversely,may generate in the populace cynicism and distrust toward the political system.
Belgiumin late 1944 providesa good illustrationof the importanceof action against the membersof the outgoingregime.The political elite who
returnedto power in September1944 had many reasonsto organizethe
elimination of the Germanophilecollaboratorsas efficiently as possible.
The legitimacyof the reinstatedleadershippartlydependedon the speed
and the thoroughnesswith which the unpatrioticgoverors of occupied
Belgiumand their followingwere ousted from the political and public forums.18But the returningelite also knew that its authorityand legitimacy
were challengedby a new and unquestionedpower, the resistancemovements. It had to avoid everypoliticalmove that could push the resistantsin
the directionof revolutionaryaction.19Any suggestionof weaknessin the
government'shandling of the collaboratorswould certainlyhave been an
affrontand a provocationin the eyes of the resistancemovements.Impu15. VaclavBenda,an activedissidentunderthe communist
regimeandin 1992chairthe mainaimbehindthe Csechoslovak
manof the ChristianDemocratic
Party,described
considered
fromthe viewpointof Czechoslovak
democracy
ScreeningAct as "self-protection
andfromthe viewpointof the evolutiontowardsa marketeconomyand a stateof law."
5 EastEur.Rep.42, 42 (March-April
1992).
Interview,
theGhostsof the Past,"Rep.E. Eur.,14June1991,at
16. SeeJanusz
Obrman,
"Laying
12.
ThirdWave213.According
17. Huntington,
to JuanMendez,generalcounselof Human
to dealwithsuchdifficultandtouchysubjectswill
RightsWatch,"Theabilityof institutions
in the citizenryaboutthe country's
instillconfidence
capacityto buildreliableandtrustworinstitutions."
Citedin Boraine,Dealing
92.
thydemocratic
18. A complicating
factorwasthatmanycollaborators
belongedto politicalmovements
REXin Francophone
(VNVin Flanders,
Belgium)thathadwonbetween15%and20%of
theparliamentary
seatsin the prewar
nationalelectionsof 1936and1939.Thesemovements
hadthuslongbeenredoubtable
forpower.See WilliamBrustein,
"ThePolitical
competitors
of BelgianFascism:
The Caseof Rexism,"
53 Am.Soc.Rev.69 (1988).
Geography
19. SeeGeoffryWarer,Lacrisepolitique
1944:Uncoupd'6tat
belgedenovembre
manqud?
(Brussels:
CRISP,1978).
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the sole or even the most importantone, for formingthe collective moral
conscience."26
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but ...
that to leave the past alone is the best way to avoid upsettinga delicate
processof transitionor to avoid a returnto pastdictatorship.The attitudeis
that there is a dragonliving on the patio and we had better not provoke
it."47
A prolongedphysicaland social expulsion,basedon criminalcourtdecisions, of certainsections of the populationmay obstructdemocraticconsolidationin yet anotherway. It could drive the supportersof the previous
regime into social and political isolation.This in turn could result in the
creation of subculturesand networks,which in the long run will become
hostile to democracy.Criminalprosecutionsmayalso precludethe reconciliation neededfor a democracyto function.The need for closing the ranksis
one of the main arguments of advocates of amnesty laws.48
The viabilityof a youngdemocracyalso dependson its efficacy.A farreachingpurgeof administrativeand managerialmanpowercan be counterproductiveas it endangersthe badlyneeded political and economic development of the country. Prudent considerations of the problematic
consequencesof dismissalsfromcivil servicejobsare heardin Eastand CentralEuropetoday.49When a bill on lustrationwasdiscussedin the Bulgarian
Parliament,VirginiaVeltcheva, one of those workingon the draft,said:"It
is unthinkablethat the law should directlyaffect more than one hundred
people. We cannot depriveourselvesof specialists,though they may have
workedfor the previousregime."50
Poland'sPresidentWalesahas repeatedly
with
the
lustration
opposed
argumentthat "itwoulddeny skilledprofessionDemocracies28-32 (Baltimore:Johns Hopkins University Press, 1986) ("O'Donnell &
The next continent wherethe problemwill manifestitself
Schmitter,TentativeConclusions").
is Africa.South Africaand Ethiopia,amongothers,mustdecidehow to settle a past account
withoutupsettinga presenttransition.(On South Africa,see in this issueLynnBerat& Yossi
Shain, "Retributionor TruthTelling in South Africa?Legaciesof the TransitionalPhase,"20
Law & Soc. Inquiry163 (1995).) A generalintroductionto this issue can be found in Ali
Mazrui,"ConflictResolutionand SocialJusticein the Africaof Tomorrow:In Searchof New
Institutions,"127-128 PresenceAfricaine308-28 (1983), and id., "TowardsContainingConflict in Africa: Methods, Mechanismsand Values"(presentedat Organizationof African
Unity workshopon conflict managementin Africa,Addis Ababa,May 1993) ("Mazrui,'TowardsContainingConflict'").
47. Rosenberg,in Dealing66 (cited in note 35).
48. See UruguayanPresidentSanguinetti'sjustificationof an amnesty law pardoning
abusesof a previousmilitaryregime:"TheUruguayangovernmenthas decidedto take measuresof magnanimityor clemencyusinga mechanismprovidedfor in the Constitutionof the
Republic.The 12 yearsof dictatorshiphave left scarswhich will need a long time to heal and
it is good to begin to do so. The countryneedsreconciliationto face a difficultbut promising
future"(cited by Orentlicher,100 YaleL.J. 2545). The sameargumenthas been usedby South
AfricanPresidentMandelain defenseof his amnestyproposals.
49. Offe, 33 Arch.Eur.Soc. at 198. Offe also noted that EastGermanyis special in this
regard"asit can affordthe replacementof largenumbersof formerofficialsand professionals
given the supplyof such personnelof at least equal skills that can be importedfrom the
West."
50. Cited in VenetaYankova,"Democracy's
FirstSteps,"5 EastEur.Rep.44, 44 (1992).
Yankova,a Bulgarianjournalist,adds,"thosedemandingpurificationof public life have no
idea of the social cataclysmthey might be provoking."
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DIFFERING POLICIES
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Netherlands,retroactivitywas clearlypresentin the reintroductionof capital punishment.The three countriesalso espousedthe principleof collective guilt through the disqualification of people because of their
membershipin collaborationistmovements.In addition,curtailingthe right
of defense took place throughrestrictionsof access to appealcourtsand of
contacts between lawyersand their clients and in the form of arbitraryarrests and of prolongedinterments.69Layjudgesparticipatedin the activities of the tribunalsthat triedthe collaborators.Franceincludedmembersof
the resistancemovementsin two of the newly createdkey institutionsof the
purge,the Coursde Justiceand the ChambresCiviques.The Dutch set up
some 35 Special Courts,with two of the five judgesbeing armyofficers;for
lesser cases of collaboration,tribunalswere createdwhich were staffedby
two patrioticcitizens and one professionaljudge.The Belgiangovernment
in exile and its immediatesuccessorsturnedto the alreadyexisting military
courtsand madethem competentfor the trialof collaborators.Three of five
membersin each court were armyofficers.70
Rule of law considerationshave receiveda much more markedattention in Czechoslovakia,Hungary,and Poland.This has been clearlyvisible
in the public debatesthat accompaniedthe draftingof screeningacts and
the eventual lifting of the statute of limitations.The latter problemhas
been vigorouslydebatedin Hungarywherea law, passed4 November 1991,
lifted the 30-year statute of limitation for offenses of treason, voluntary
manslaughter,and fatal injurycommittedbetween21 December1944 and 2
May 1990, if the communistauthoritieshad not prosecutedfor political
reasons. The law was particularlyaimed at making prosecutionpossible
againstthe men who were involved in the bloody suppressionof the 1956
uprising.Oppositionto the law was heavy, both in political and academic
circles. Legal scholars,who fought the law, based their reasoningon such
concepts as legal certainty,nonretroactivityof criminallaw, and the new
Hungarianconstitutionand found no reasonto lift the time-basedlimitation on the state'srightto punish.71After the bill waspassedin Parliament,
the Hungarianpresidentaskedthe constitutionalcourt to rule on the law's
constitutionalitybefore it was promulgated.The court rescindedthe law,
But in February1993,
citing eight specificcounts of unconstitutionality.72
numerousin the case of The Netherlands.See
69. These infringementswereparticularly
105-8 (cited in note 60).
Belinfante,In plaatsvan bijltjesdag
70. In May 1944, three monthsbeforethe Liberation,the Belgiangovernmentin exile
decidedto revoke its decision to includemembersof the resistancein the militarycourts.It
did so aftervigorousprotestsby the auditeur-g6n6ral
(the magistratein chargeof the military
court system).
71. See the ProfessionalOpinion, preparedfor the PrimeMinisterby six professorsof
LorandEotvosUniversity'sLawFaculty(documentsent to the office of the PrimeMinister
on 12 Aug. 1991 and presentedat a PragueConferenceon Restitutionand Retribution,Dec.
1991).
72. See interviewwith LaszloSolyom,presidentof the constitutionalcourt,in EastEur.
Rep., March-April1992. Confrontedwith the objectionthat the court'sdecisiondid not take
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the parliamentvoted two new laws, one dealing with crimes committed
immediatelyafter the 1956 uprisingand another with crimes against humanity,committedby communistleadersbetween 1944 and 1989. In both
cases the legislationstipulatedthat the courtsmustdecidewhetherthe statute of limitationsappliesin a specific,individualcase. The Hungarianpresident then againcalled on the constitutionalcourtto reviewthe new laws.It
ruledthat only the articlereferringto warcrimesand crimesagainsthumanity as definedby the Geneva Conventionwas not unconstitutionaland that
only in that case did retroactivityhave to be accepted.73In Czechoslovakia
the so-calledlustrationlaw of October 1991 introduceddisqualificationon
a groupbasis.The law was criticizedbecauseit ascribedcollective guilt and
becauseit did not include a clause allowingdisqualifiedpeople to seek redressbeforean independentappealscommission.74
Opponentsof the lustration proceduresalso blamed the fact that the files of the State Security
Agency (StB) were used as the principalevidence in determiningwho had
collaborated. These files, they said, were totally unreliable. Tens of
thousandsof namesof "candidatesfor collaboration"were circulated,causing greatdamageto individualsand organizations,without deliveringhard
proof.75After the dissolutionof the country,however,the Czechparliament
voted a new, much more restrictivelaw. In Slovakia, too, lustrationhas
slowed down considerably.Respect for the rule of law also shows in the
prominentrole the constitutionalcourtshave had in reviewingthe constitutionalityof recent legislationon communistcrimes.The Czechoslovakian
ConstitutionalCourt has askedto jettison some partsof the screeningact.
In Hungary,the Courtdeclaredthe legislationon lifting the statuteof limitations unconstitutional.In Poland,the ConstitutionalTribunalsuspended
the implementationof the Sejm'sresolutionof 19 June 1992 that the lists of
secret service collaboratorsshould be revealed.
PostwarBelgium,France,and The Netherlandsreacted to the chaljusticebringswith it in a verystraightforward
lenges that post-authoritarian
was
full
to
way:
priority
given what madea severeand swift purgepossible,
even if this involved neglectingrule of law principlesand political risks.By
contrast,postcommunistcountrieslike Czechoslovakia,Hungary,and Poland have tended much more to a balancing act. Such differencesneed
explaining,which is the subjectof the next section.
accountof justicefor the masses,Solyomresponded:"Takinginto accountthe publicmood is
a political task, not one for the ConstitutionalCourt."
73. See 3 EastEur. Const. Rev. 10 (Spring1994).
74. PaulineBren,"Lustrationin the Czech and SlovakRepublics,"2 RFE/RLRes. Rep.
1 RFE/RLRes. Rep.,
16, at 17. See alsoJiriPehe, "Towardthe Rule of Law:Czechoslovakia,"
3 July 1992, at 10.
75. For a generaldiscussionof the reliabilityof state securityfiles in judgingpriorregimes, see the reportof the 30 Oct.-1 Nov. 1992 Budapestmeeting (cited in note 9). The
Kafka-likedimensionsof lustrationbasedon state securityfiles arewell describedin Lawrence
Weschler,"TheVelvet Purge:The Trialsof Jan Kavan,"New Yorker,19 Oct. 1992, at 66-96.
III.
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that this episode in the historyof their countrieshas made the post-1989
elites somewhatallergicto post-transitionprosecutions.
International Context at the Time of the Transition
Retrospectivejusticein Belgium,France,and The Netherlandscame at
a time when supranationalcodes with respectto humanrightsand the rule
of law were either weak or absent. This has changed considerablysince
then. The Council of Europepublishedits Conventionfor the Protectionof
HumanRightsand FundamentalFreedomsin 1950. Latercame the International Convention on Civil and PoliticalRightsand the HelsinkiAccords.
Surveillanceand monitoringbodies, rangingfrom supranationalcourts to
the InternationalHelsinki Committee, have become operational.84This
new legal frameworkhas been and still is of great importancein decisions
dealing with the past in Czechoslovakia,Hungary,and Poland.Czechoslovakia'sScreeningAct has been critizedby three internationalagencies:the
Council of Europe,the InternationalHelsinkiCommittee,and the International LaborOrganization(becausethe law violated article 111 of the ILO
convention on discriminationin the workplace).85
It is not clear if and how
these criticismshave affectedthe furthercourseof lustrationin that country, but they certainlyhave been used in the domesticdebate by the law's
opponents. More significantis that, apartfrom any referenceto international censure,governments,parties,judges,and legal scholarsin Czechoslovakia, Hungary, and Poland have regularly invoked international
conventions on human rightswhen preparingor reviewingcriminalor lustration laws. In Poland,for example,a local Helsinki Committeehas been
set up and its proposalsfor proceduralguidelineshave receivedgreatattention in the debate on screening.86The Hungarianpresidenthas asked the
constitutionalcourtto reviewtwo articlesof the February1993 law (on the
lifting of the statute of limitations)for their conformitywith article 7.1 of
the EuropeanConvention of Human Rights and with article 15.1 of the
InternationalConvention on Civil and Political Rights. A strong motive
for not neglecting the signals coming from abroadis the possibilitythat
violationsof rule of law codes might compromisethe country'smembership
of the Council of Europe.87
84. Fora generalintroductionto the role of internationalorganizationsin transitionsto
democracy,see the Journalof Democracy's
special issueon the subject(vol. 4, no. 3, 1993).
85. Bren,RFE/RLRes. Rep. at 21 (cited in note 74).
86. See AndrzyRzeplinski,"A LesserEvil?"1 EastEur. Const. Rev. 33, 33 (Fall 1992).
87. In the postcommunistcountries, internationalsupervisionof transitionaljustice
leads to proceduralguaranteesfor those who are subjectedto prosecutionand lustration.In
other circumstances,such as in transitionsto democracyin LatinAmericaand in Africa,the
internationallegal environmentcan also ensurethat graveviolationsof humanrightsdo not
remain unchallenged.Variousways are open here. One is illustratedby the U.S. Torture
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to an authenticreconciliation
andan invitationto recidivism.
impediment
Thatis whymostanalystsarguethatif the balanceof forcesat the timeof
the transitionmakesa negotiatedmildnessinevitable,a truth-telling
operation withfullexposureof the crimesof the formerregimeis the leastunsatisfactorysolution. As one Pragueprofessorof law wrote: "We may
eventuallydecideto offeramnestyto someor all of ourformeroppressors,
butbeforewe forgive,we shouldknowwhatevil we areforgiving,andwho
caused it."94"Memory,"says RogerErrera(memberof the FrenchConseil