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07.05.2005

The Armenian Genocide Revisited:New Perspectives in International Law

   

Richard Giragosyan

The study of the Armenian genocide has produced a broad body of work on a wide array of diverse aspects of the events of 1915, with each serving to forge a richer historical narrative of increasing depth and detail. There has also been significant attention devoted to the role of the Armenian genocide as precedent and precursor for subsequent cases of mass atrocity, genocide, and holocaust. This task of articulating and interpreting the “internationalization” of the Armenian genocide is, in many ways, the most effective avenue toward demonstrating the relevance of the Armenian genocide. This is particularly important given the passage of ninety years, and its resulting transition from personal memory to collective history.

There is another factor that enhances both the significance and relevance of the Armenian genocide, however. Despite the broadening distance of time, 1915 retains its linkage to 2005. Ironically, it is the Turkish state that helps to contribute to the continued vitality and significance of the Armenian genocide and, by both default and by design, serves to raise the issue to a strategic concern. This is accomplished through Turkey’s state-sponsored policy to confront and refute the historical record. Although this effort is impeded by a reliance on a selective misinterpretation of history, it succeeds in reaffirming, and even magnifying, the relevance of the Armenian genocide. It also elevates the genocide from an unrecognized, to an unresolved, burden for modern Turkey.

The Internationalization of the Armenian Genocide

Within a broader context, there has been a dramatic and abrupt shock to the system of global security driven by the events of September 11, 2001 and the subsequent “war on terrorism.” The impact of September 11th forced a sudden shift in the international system, resulting in a series of sweeping changes to the geopolitical landscape of the post-Cold War world. The aftermath of September 11th continues to exert a powerful influence on the course of international relations, and just as significantly, offers a new role for international law.

These two new trends, of altered international relations and of enhanced international law, offer the most important opportunities for a reaffirmation and “internationalization” of the Armenian genocide. At the same time, however, the intersection of these two trends also threatens to obscure the Armenian genocide, relegating the issue as a hostage to the greater demands and needs of international security.

International Relations in an Age of Terrorism

There is also a danger that this enhanced focus on international security will complicate, or even impede, the effective prevention of genocide in the future. This danger stems first from the current trend of forging alliances and tactical partnerships with states of questionable or dubious integrity. Such new allies in the war on terrorism include a number of regimes that are, or may be, tempted to use the threat of “international terrorism” as a justification for their own campaigns against ethnic groups or minorities. There is a real possibility for a renewed pattern of ethnic conflict, or even genocide, under the guise of security and stability.

The danger in this age of terrorism also stems from a second factor, consisting of a willful disregard for international norms and standards, which has already arisen. On a general level, the U.S. has prosecuted its “war on terror” with a reliance on measures grounded in an approach of unilateralism and preemption. This has included a tendency to turn to the multilateral institutions of international security only when and where convenient, and has featured an arrogant disdain for international laws and conventions, such as the Geneva Conventions.

This selective conformity to international law has fostered an atmosphere that has produced such incidents as the abuse of detainees at the U.S.-run Abu Ghraib facility in Iraq or as seen by the arbitrary definition of who or what constitutes an “enemy combatant.” Such a record of inconsistent readings of the Geneva Conventions, as a subset to an ideological approach of “good versus evil” in countering international terrorism, only threatens to derail the gains in international law and security that has been fitfully achieved since the end of the Cold War. It has also produced such legal “black holes” as the Guantanamo prison facility that affords neither due process nor prisoner of war status to its unknown number of detainees. The implications for the Armenian genocide, whose sole merit rests on an appeal to international law and justice with little or no geopolitical value, is worrisome indeed.

New Opportunities in International Law

Yet amid the recent expansion of international security and the extension of the military as the main tool of statecraft, the last decade has also been marked by a steady strengthening of the system of international law. Rooted in the need to deal with the genocide in Rwanda and the ethnic cleansing in the Balkans, this emerging system of international criminal law has also become institutionalized, with the formation of the new International Criminal Court (ICC) in 2002. This process of an emerging institutionalized legal system is also an important step toward the creation of effective bodies capable of enforcing the standards and norms of international law.

The evolution of a system of international criminal law is a modern development and, as seen in the case of the Armenian genocide, was notably absent prior to World War II. It is, therefore, instructive to trace the development of international criminal law as it offers several trends that mirror the problematic course of recognition and reaffirmation of the Armenian genocide. It also reveals the inherent risk of an overly politicized process of international law, which tends to result in a sacrifice of international justice in service of international relations.

The point of origin of this system of international law was the post-war creation and implementation of the Nuremburg trials of former officials and leaders of Nazi Germany. Conducted within the parameters of an international military tribunal, the Nuremburg process was actually a criminal proceeding primarily focusing not on the atrocities of the holocaust, but on “Nazi aggression and militarism.”1

Although the Nuremburg process initially failed to affirm a law of atrocity, it did establish an important “foundation for contemporary international law on war crimes.” 2 But this first step in forging an institutionalized approach to enforce international law was seriously limited. The Nuremburg trials resulted in the indictments of a mere twenty-two defendants and its parallel effort in Japan, the International Military Tribunal for the Far East (more commonly known as the Tokyo Tribunal), was impeded by a priority on achieving political goals and a preference for securing stability over justice. By 1953, for example, most of those convicted by the Tokyo Tribunal were released and, by the next year, two of those convicted for war crimes were elected as prime minister and foreign minister of Japan.

In the wake of these overly politicized post-war tribunals, the evolving system of international law was relegated to a secondary role in service to the geopolitical agenda of the Cold War. The Armenian genocide, as the leading example of unresolved justice in this period, remained hostage to the broader demands of Cold War confrontation and its significance was never allowed to overshadow the Western reliance on its “loyal Turkish ally.”

New Perspectives in International Law

The end of the Cold War period ushered in a new era, however, with an emphasis on reexamining much of the structure and many of the institutions of international law and security. Such a new impetus led to the empowerment of the Conference for Security and Cooperation in Europe (CSCE), a shift in mission and structure for the North Atlantic Treaty Organization (NATO), and was matched by an ongoing expansion of the European Union. The idols of democracy and free markets were seen to be surpassing the ideals of geopolitics.

Another significant feature of this post-Cold War shift in international security was a related focus on international law as a standard for state conduct and relations. Within this context, there was an effort to forge a globalized criminal process, mainly to meet the rise of “ethnic conflict” and “ethnic cleansing” challenging the concept of Western security in the Balkans and stability in the former Soviet Union. Marking a highpoint of this period, the International Criminal Court (ICC) was created as “a permanent institution mandated to investigate and prosecute the most serious crimes of international concern, namely genocide, crimes against humanity, and war crimes.” 3

As of March 2005, 139 nations had signed and 97 had become parties to the Rome Statute empowering the International Criminal Court (ICC). Ironically, the most notable exception to the ICC was the United States, which had exempted itself from the ICC, resolving that its national interest would be better served by preventing the ICC from holding jurisdiction over any U.S. soldier or official. This exemption has been more recently reinforced through a set of over ninety bilateral accords on immunity, and related “status of forces” agreements which proscribe foreign jurisdiction over U.S. military personnel.

In addition to the creation of the ICC as an international court, there was also a proliferation of a number of ad-hoc courts and tribunals dealing with international crimes. The jurisdiction and workload of these tribunals was daunting, covering crimes of atrocity in Cambodia, East Timor, Kosovo, Rwanda, Sierra Leone, and the former Yugoslavia. Some of these bodies have been stand-alone international tribunals and others formed as hybrid panels with the joint participation of the United Nations and local national courts. The multiplication of these new institutions, in the words of Leyla Sadat, offered a new “constitutional moment” of international law dominating the international political order. 4 This linkage between international law and security is also evident in the latest creation of a unique legal body, the Special tribunal for Iraq, empowered to prosecute systemic human rights abusers during the Saddam Hussein period but also endowed with supremacy over crimes against humanity, war crimes and genocide.

This trend toward institutionalizing international law is not without its critics, however. Drawing mainly from American political scientists of the “realist” school, these critics include such dominant figures of U.S. foreign policy as George Kennan and Henry Kissinger, who contend that international law should only serve as a guide to promote cooperation, but not govern relations, between nation states. Combined with the current dominance of U.S. unilateralism and preemption, this ideological preference for national interest over international law suggests a difficult path toward an international system defined and defended by the tenets of international law.

New Perspectives in National Law

As the course of international law has been expanding and strengthening in recent years, there has also been an interesting trend of judicial activism within national courts. National courts have been increasingly “invoking principles of universal jurisdiction” involving cases that “assert jurisdiction over foreign perpetrators of systemic human rights abuses against foreign nationals.” 5

One of the more prominent examples of such cases involved a judicial extradition request lodged by the Spanish court seeking to try the former Chilean leader, General Augusto Pinochet. The Spanish court sought to secure jurisdiction while Pinochet was undergoing medical treatment in the United Kingdom. The October 1998 extradition request was based on the Spanish judiciary’s allegations of Pinochet’s culpability for a pattern of serious human rights abuses and violations during the period of his rule in Chile from September 1973 to March 1998.

The Pinochet case raised a number of bold new points in international law and justice, centering on the premise of sovereignty and sovereign immunity inter alia. The legal issue centered on whether a head of state (either currently or formerly in power) holds absolute immunity under international law from proceedings in the courts of other nations for his actions while in power. While the Pinochet case also raised secondary questions pertaining to venue and jurisdiction, it affirmed an enhanced role of national courts within the context of international law. This was also an important new opportunity for expanding the options for securing justice in cases of international human rights violations and genocide.

Expanding Jurisdiction

This concept of expanded jurisdiction was further addressed in a ruling by the International Court of Justice (ICJ) on a case involving the legality of a Belgian arrest warrant issued for a Congolese state minister in 2002. The ICJ ruling determined that the doctrine of official immunities, as contained within customary internal law, limited the reach of a foreign national court over an accused human rights abuser who was serving as a head of state or official at the time of the alleged abuses. The successful invocation of the defense of official immunity under customary international law has been substantially narrowed in recent years, however, and even eliminated, as rulings of the ICC and the tribunals for Rwanda and the former Yugoslavia have affirmed. 6

The interpretation of the jurisdictional question between the International Criminal Court (ICC) and national courts aspiring to pursue such ex post cases is governed by the concept of complementarity, which grants the ICC jurisdiction only in cases where it views national courts as unwilling or unable to investigate or prosecute. The most recent development in terms of such expanded jurisdiction was the decision by the U.S. Supreme Court regarding the scope of the Alien Tort Statute (ATS). In a decision at the end of its 2004 term, the Supreme Court issued a ruling in a case (Sosa v. Alvarez-Machain) that posed a jurisdictional question determining the suitability of applying international law claims. It was not the case in and of itself that holds any significance for the Armenian genocide, however, but the underlying body of law that was used in the Supreme Court’s adjudication.

The Alien Tort Statute (ATS)

One of the fundamental examples of convergence between U.S. federal and international law is the little known Alien Tort Statute (ATS), also known as the “Alien Tort Claims Act.” This statute was enacted by the first session of the U.S. Congress as part of the Judiciary Act of 1789 which first established the U.S. federal court system. It remained largely dormant for two hundred years after its passage, emerging only once in a legal proceeding. The Statute grants U.S. federal circuits “original jurisdiction of any civil action by an alien for a tort…..committed in violation of the law of nations.” 7

The Alien Tort Statute was not invoked until a 1980 case (Filartiga v. Pena-Irala) before the Second Circuit sought damages from former state officials of Paraguay in a civil action brought by a group of Paraguayan citizens. The court first chose to hear the case, which alleged torture as the basis of a violation of customary international law, on the grounds that the ATS provided jurisdiction based on the fact that the case “was filed by an alien,” alleged a “violation of the law of nations,” and provided a cause of action because it viewed international law as “part of the federal common law.” 8

This precedent provided a new avenue for judicial redress by foreign citizens for an array of abuses committed by foreign governments. The subsequent use of this Filartiga case was rapidly used in cases filed against a sitting president of Zimbabwe, a former president of Philippines, a former Chinese prime minister, as well as former military leaders of Guatemala, Ethiopia and Nigeria. 9 Litigation based on the Alien Tort Statute was further expanded to include cases against foreign and American corporations, sued for violations of human rights and environmental standards. 10

This expanded use of the Alien Tort Statute (ATS) was reigned in by the Supreme Court’s 2004 decision, however. In its ruling on the Sosa v. Alvarez-Machain case, the Supreme Court rejected as “frivolous and implausible” the argument that the ATS authorizes the “wholesale incorporation of substantive” standards of customary international law “into U.S. law as part of federal common law.” 11

The Supreme Court ruling did allow for some degree of latitude in terms of jurisdiction, however, and set forth some flexibility in future cases involving a recognized yet narrowed subset of crimes against “the law of nations.” These crimes, derived from the original historic intent of the law, comprised three specific areas: offenses against ambassadors, violations of safe passage and piracy. Ironically, it is the last crime, piracy, which is relevant for the prosecution of crimes of atrocity, including genocide.

This relevance of “piracy” to genocide stems from the legal interpretation of piracy that, by its very nature, is a crime closest to modern human rights violations. Piracy is also the only universal jurisdiction offence known to both common law and the law of nations. 12 And by serving as a benchmark for judicial recognition of new international norms, piracy can be legally equated with the category of foreign (and transnational) crimes of terrorism, atrocity and genocide.

Shared Traits of Genocide: Ideology and Geography

Overall, the record of genocide prevention remains seriously deficient. The crimes of mass atrocity, manifested through incidents of genocide, ethnic cleansing and minority- or racial-based violence, share a set of fundamental traits. These shared traits range from ideology, through a campaign of violence and killing often justified under cover of extreme nationalism, to geography, often manifested in countries that suffer from a failure or loss of state authority and power, i.e. “failed states.” In terms of international law, acts of atrocity are interpreted as “crimes against the world community” and constitute an important new branch of international law known as the “law of atrocity.” 13

In terms of both ideology and geography, genocide knows no limits. State borders are meaningless, as genocides often spill over into neighboring countries, and the severe hatred behind the crime extends beyond the conceivable. Additionally, all acts of genocide share another factor- a lack of political will among the international community to act, to intervene, or even to oppose genocide. Thus, genocide, ethnic cleansing and minority-based communal violence are all derivatives of the same hatred masked in extreme nationalism. This linkage is shared by the genocides and genocidal acts that have occurred in the cases of the Armenians, the Bosnians, the Cambodians, the Jews, the Kurds, and the rest of an appalling alphabetical list of victims.

At the same time, however, each act of genocide is unique as a cumulative product of dynamic factors stemming from demographics, economics and politics. This is essential for the crafting of an effective response to genocide, both during and after the act. In this way, reconciliation in the post-genocide phase is often impeded by unresolved factors that gave rise to the genocide in the first place. And with the case of the Armenian Genocide, one of the more serious impediments to reconciliation is the policies of political denial and historical revisionism by the perpetrators.

Parallels to Rwanda

The genocide in the African nation of Rwanda marked a low point in the modern prevention of crimes against humanity. With a distressing record of inaction and inattention, the United States emerged as a prime example of the problem of timidity of states in the face of atrocity and genocide. Although the U.S. was not alone in its failure to respond to what was clearly genocide, it was notably absent from its role as a leader of the international community. The disturbing record of U.S. inaction was most effectively revealed by Samantha Power in her groundbreaking 2002 work “A Problem from Hell:” America and the Age of Genocide, whose opening lines notably begin with the story of the Armenian genocide. 14

The specifics of the Rwanda genocide are particularly damning. From April to July 1994, a government led by extremist elements of the Hutu ethnic tribe carried out a campaign of genocide targeting ethnic Tutsis in which 800,000 of their fellow Rwandans, or roughly ten percent of the total population, were killed. The sheer scope and scale of the 100-day Rwandan genocide was astounding, with a rate of killing triple that of the Nazi holocaust and involving up to a million perpetrators, accomplices and facilitators.

Ethnic Hatred and Incitement

The Rwandan case also demonstrates that genocide and mass atrocities do not erupt randomly, but necessitates prior organization, coordination and implementation. There is also an important prerequisite of incitement, most often through the use of a “propaganda of hate” which serves to demonize and dehumanize the target people or group. This also involved the utilization of modern technology, as in the cases of Rwandan radio and with the use of cell phones to coordinate attacks in the Balkans.

Although not nearly as potent or as overt, Turkish policies of revisionism and denial display a similar “group hatred” and incitement by labeling the Armenian genocide as an attack against the Turkish state. This stems from a tendency of the Turkish state to exaggerate the “Armenian threat” and exploit popular insecurity. In many ways, the accumulated effect of such constant anti-Armenian incitement is one of the more serious longer term obstacles to Turkey’s potential acceptance and management of the issue of the Armenian genocide.

The Failure of State Response

Another troubling aspect of the Rwandan genocide was the failure of an immediate or effective response by the international community. In times of crisis, the illusion of any concept of an international community is most evident. What has been commonly accepted as the international community is, in reality, nothing more than a diverse group of nation states, each pursuing their own diverging national interests and engaging in state competition much more often than cooperation. The failure of responding to the Rwandan genocide therefore, was more one of state failure. And given the post-Cold War realities, the United States was especially deficient.

The failure of the U.S. response to Rwanda is also mirrored by its handling of the Armenian genocide. The U.S. State Department handled the Rwandan genocide with a bureaucratic hesitance and political timidity that reflects its diplomatic record on the Armenian genocide. In both cases, the U.S. failed to come to terms with, or even accept, an interpretation of genocide. Although in the Rwandan case this was largely due to its reluctance to shoulder the moral responsibilities that such an affirmation would entail, its policy on the Armenian case is tainted by an overriding preference for appeasing Turkey over affirming the historical record.

Adjudicating the Rwandan Genocide

A full four months after the conclusion of the Rwandan genocide, the United Nations Security Council established the International Criminal Tribunal for Rwanda (ICTR) to investigate and prosecute “persons responsible for genocide and other serious violations of international humanitarian law committed on the territory of Rwanda, and Rwanda citizens responsible for genocide and other such violations committed in the territory of neighboring states, between January 1, 1994 and December 31, 1994. 15

One of the most significant achievements of the ICTR was its work in addressing theories of individual culpability in terms of collective action. This was an important examination of the legal concepts governing the concept of group sanction. Specifically, the concept of group sanction includes an element of collective guilt, whereby international criminal law assigns liability in cases of genocide and mass atrocity to the perpetrator group, attributed to a state, or to a specific ethnic, racial, religious, or political group. 16 But there is a deeper aspect of group sanction, which flows not from collective guilt but from collective liability. It is this aspect of group sanction that Law Professor Mark Drumbl recommends revising, to adopt a “perspective that treats victims as individuals and aggressors in the collective (instead of international criminal law’s current focus on victims in the collective and aggressors as individuals).” 17

This concept is particularly applicable to the adjudication of the Armenian genocide because it expresses a remedy that not only stigmatizes the active and passive involvement in genocide, but also focuses on the need to “restore” the victims, an element missing from the standards of retributive criminal law systems. According to Drumbl, this approach would “structure group sanction around the notion of collective responsibility, which differs from collective guilt, blame or liability.”18

Lessons for the Armenian Genocide: Novel Remedies

For the Armenian case, this allows for the crafting of a case-specific remedy that overcomes the passage of time and the absence of direct perpetrators. Moreover, such a new innovative focus on collective responsibility offers a set of “restorative, commemorative and reparative approaches” that meet the minimum standards of justice inherent in the Armenian genocide. 19

Another relevant issue for the Armenian genocide from this consideration of new remedies is the concept of “penological justification.” There are two central elements that constitute the rationale for punishment in cases of genocide or atrocity. The first element, retribution, holds that the imposition of punishment corrects the moral balance as long as it is both fair and proportionate to the gravity of the crime. The second element, deterrence, is more forward-looking and defines the purpose of prosecuting and punishing those who commit the atrocity as dissuading and deterring others from carrying out such crimes in the future.

In the case of the Armenian genocide, the reality of the twin challenges of distance and delay, in terms of the passage of time and the passing of the perpetrators, poses a distinct challenge to this concept of punishment. Thus, the applicability of the first element of retribution rests on fairly weak legal ground, while the second element of deterrence is a more dominant consideration. Specifically, the deterrence aspect of adjudicating the Armenian genocide provides an important subset of issues that offer significant remedy and redress, and include measures promising potential rehabilitation and reconciliation.

This is also one of the core goals of the tribunal or “Truth Commission” empowered by the UN to deal with atrocities in East Timor, which seeks to leverage the judicial process of prosecution and punishment to foster reconciliation as much as to render justice. A corollary goal common to both the Armenian and East Timorese cases is the need for redemption and reconciliation. This need has been well established in political science and, as shown in a study of civil conflict and reconciliation in six Latin American and four African states, includes a social healing process led by a “forgiveness process characterized by truth telling, redefinition of the identity of the former belligerents, partial justice and a call for a new relationship.” 20

The role of apology within a comparative international context was also studied by Syracuse Law Professor Hilary Josephs. 21 In her analysis, Josephs utilized the work of Hiroshi Wagatsuma and Arthur Rosett in using law as an instrument for nonviolent conflict resolution, as in the case of Japan and the United States. 22 The specific role of apology is also explored, with a recognition that “different modalities for reconciliation exist.” 23 This is further developed in the work of Janna Thompson, who distinguishes reparation as restoration and holds that symbolic acts like apologies can count as reparations. They do not restore lives that have been lost or bring it about that suffering did not happen. But by demonstrating a remorseful acknowledgement of a past wrong, they can make it possible for nations or individuals to reestablish relations of respect. 24

Of course, this is not to say that the question of justice for the crime of genocide can be reduced to a simple apology. The point is one of redress, but it is also one of adopting a more flexible approach to the issue of reparations. In the case of the Armenian genocide, the unresolved demands of restitution and reparation, as well as the unsolved demands of reconciliation and restoration, must be addressed. But realistic justice for the Armenian genocide can not be blind to the limitations of demography and geography, coupled with the passage of time.

In this way, it may be argued that the judicial process is more important than the judicial sentence. It may also be the only way, given the nature of international law as a process that punishes individuals for actions committed on behalf of the state. 25 This effectively replaces the state as the traditional subject of international law with the individual. But for the Armenian genocide, without legal recourse to arraigning individuals, legal standing is dictated by the responsibility of the state, or more precisely in the case of Turkey, by the responsibility of the “inheritor state.” Thus, it is imperative for Turkey as the inheritor state to assume the burden of the past before looking to a new future.

1 Douglas, Lawrence, The Memory of Judgment: Making Law and History in the Trials if the Holocaust. (Yale University Press: 2001), P. 93.

2 Sands, Phillipe, Ed. From Nuremburg to the Hague: The Future of International Criminal Justice. (Cambridge University Press: 2003). P. 28.

3 Rome Statute on the International Criminal Court, United Nations Document A/CONF.183/9 (1998), http://www.un.org/law/icc/statute/romefra.htm.

4Sadat, Leila. The International Criminal Court and the Transformation of International Law: Justice for the New Millennium, (Transnational Publishers: 2002) P.1.

5Ibid, P. 130.

6Sands, (2003), Pp. 89-102, 108.

728 U.S.C § 1350.

8 630 F.2d 876 (2d Cir. 1980)

9Kontorovich, Eugene, “Implementing Sosa v. Alvarez-Machain: What Piracy teaches About the Limits of the Alien Tort Statute,” Notre Dame Law Review, Vol. 88, November 2004, P. 8.

10 Ibid, Pp. 8-9.

11 Ibid, P.2.

12 Ibid, P.4.

13Drumbl, Mark. “Collective Violence and Individual Punishment: The Criminality of Mass Atrocity,” Northwestern Law Review, Vol. 99 No. 2, 2005, P. 540.

14 Power, Samantha. “A Problem from Hell:” America and the Age of Genocide. (Basic Books: 2002) Pp. 1-20.

15 United Nations Security Council Resolution 955, 49th Session, UN Doc. S/RES/955 (1994).

16 Drumbl, Mark. “Pluralizing International Criminal Justice,” Michigan Law Review, Vol. 103, 2005, Pp. 120-121.

17 Ibid, P. 121.

18 Ibid, P. 212-122.

19 Ibid, P. 122.

20 Long, William and Peter Brecke. War and Reconciliation. (MIT Press: 2003). P.3.

21 Josephs, Hilary, “The Remedy of Apology in Comparative and International Law: Self-Healing and Reconciliation,” Emory International Law Review, Vol. 18, 2004.

22Wagatsuma, Hiroshi and Arthur Rossett, “The Implications of Apology: Law and Culture in Japan and the United States,” Law & Society Review, Volume 20, 1986.

23 Josephs (2004), P.60.

24 Thompson, Jenna. Taking Responsibility for the Past: Reparation and Historical Justice. (Polity Books: 2002), Pp. 47-50, cited in Josephs (2004).

25 Weitz, Eric. A Century of Genocide: Utopias of Race and Nation. (Princeton University Press: 2003). Weitz also contends that genocide is organized by states but is only implemented through popular participation.



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