On December 16, 1990, Jean-Bertrand Aristide, a Roman Catholic priest and populist politician, was elected president of the Haitian republic. Aristide was the first democratically elected president in Haiti's politically turbulent history. Subsequently, on September 29, 1991, less than a year later, a military junta composed of Brigadier General Raoul Cedras, Colonel Aliz Silva, and Colonel Henri Marc Charles seized political power by coup d'etat. The overthrow of the Aristide regime precipitated an internal armed conflict that culminated in the weakening of the rule of law and the suppression of fundamental human rights.
Thomas D. Jones, Haitian Refugee Center, Inc. v. James Baker, III: The Dred Scott Case of Immigration Law, 11 Penn St. Int'l L. Rev. 1 (1992).