Statement of New York City Bar Association on the Assassination of Rachelle Bergeron, Acting Attorney General of the Micronesian State of Yap
New York, January 8, 2019 – The New York City Bar Association mourns the death of Rachelle Bergeron, the Acting Attorney General of the tiny Micronesian island state of Yap, who was brutally murdered on October 14, 2019 in connection with her work as the island’s chief prosecutor.[i]
A member of the New York Bar, Ms. Bergeron, 33, graduated from the University of Florida’s Levin College of Law in 2010,[ii] then worked in New York, Washington, D.C., and India, where she represented victims of human trafficking.[iii] She joined Yap’s Attorney General’s Office, an office of three attorneys,[iv] in August 2015,[v] initially accepting a position as an Assistant Attorney General.[vi] She became the island’s Acting Attorney General in January 2019.[vii] Ms. Bergeron was scheduled to leave her post and return to the United States at the end of this year.[viii]
Although she was responsible for prosecuting crimes of all types, Ms. Bergeron quickly became known as a crusader for human rights,[ix] particularly the rights of victims of human trafficking,[x] which is a scourge in Micronesia[xi] but had not been a significant focus of law enforcement prior to her arrival.[xii] As a result of her work, she was targeted by threats and in fear for her life,[xiii] and sometimes slept with a machete.[xiv] Friends and colleagues described her position as “the most dangerous job on the island.”[xv]
Ms. Bergeron was ambushed and fatally shot at about 7:15 p.m. on October 14, 2019, as she arrived home[xvi] and was opening the door on her Subaru hatchback[xvii] following her daily run with her dog.[xviii] She was shot at point-blank range twice, in the upper leg and chest, with more than 20 exit wounds.[xix] Her dog was also killed.[xx] The 12-gauge gunshot[xxi] even pierced the walls of her home,[xxii] where her husband of less than one year was baking brownies[xxiii] with a 12-year-old local girl whom Ms. Bergeron and her husband were planning to adopt.[xxiv] Hearing the shotgun blasts, Ms. Bergeron’s husband raced to her side, and, with the help of a friend, rushed her to the hospital.[xxv] However, she was pronounced dead upon arrival.[xxvi] Her husband and the young girl were not injured in the attack.
The murder has stunned the people of Yap, a former U.S. territory located approximately 4500 miles west of Hawaii and 550 miles southwest of Guam.[xxvii] The island of Yap is one of the most remote places on Earth, with a population of between 11,000 and 12,000 served by just two commercial flights a week.[xxviii] Outside the Pacific, Yap is perhaps best known for the remains of its indigenous currency, giant stones shaped like discs.[xxix]
Protocols for state funerals were observed, evidencing the island’s great respect for Ms. Bergeron. The Governor of Yap issued a series of official statements,[xxx] the legislature adopted a resolution in her honor,[xxxi] her cortege was accompanied by a police escort,[xxxii] and flags across the island were flown at half-mast in the days following her death.[xxxiii] More than 800 of the island’s residents turned out for Ms. Bergeron’s October 22, 2019 memorial service on Yap.[xxxiv] A second service was held in her native Wisconsin on November 2, 2019.[xxxv]
Police arrested two men in connection with the case, Frances Buchun (also known as Francis Buchon) and Anthony (“Tun”) Teteeth,[xxxvi] both local firefighters.[xxxvii] Authorities have lodged a number of charges against each of the suspects, including murder and conspiracy to commit murder.[xxxviii] The two are believed to have plotted the attack on Ms. Bergeron for more than a month,[xxxix] illegally procuring a 12-gauge shotgun and ammunition for use in the murder.[xl] Firearms are outlawed on Yap.[xli] Teteeth is said to have been the triggerman.[xlii]
At the time of her death, Buchon was being prosecuted by Ms. Bergeron in three pending cases,[xliii] including one involving serious charges such as “terrorizing with intent to use a deadly weapon, his firearm.”[xliv] He has previously been convicted of arson and served one month in jail.[xlv] Buchon and Teteeth are being held without bail pending trial.[xlvi]
Human rights lawyers play a singular role in society as guardians of the rule of law. Recognizing this unique status, international law accords human rights defenders, lawyers, and prosecutors like Ms. Bergeron special attention and protection.
Specifically, the United Nations Basic Principles on the Role of Lawyers charge governments with ensuring that lawyers “are able to perform all of their professional functions without intimidation, hindrance, harassment or improper interference.”[xlvii] The Basic Principles further provide that, “[w]here the security of lawyers is threatened as a result of discharging their functions,” governments are to take all measures necessary to ensure that the lawyers’ security is “adequately safeguarded.”[xlviii] In addition, the Basic Principles emphasize that attorneys “shall not be identified with their clients or their clients’ causes.” In other words, the position that an attorney advocates on behalf of a client is not to be assumed to be the attorney’s personal position and is not to be attributed to the attorney.[xlix]
The United Nations Guidelines on the Role of Prosecutors underscore these same fundamental precepts, with specific application to prosecutors in particular.[l] The Guidelines provide that governments “shall ensure that prosecutors are able to perform their professional functions without intimidation, hindrance, harassment, [or] improper interference.”[li] Further, the Guidelines charge government authorities with the responsibility for physically protecting “[p]rosecutors and their families. . .when their personal safety is threatened as a result of the discharge of prosecutorial functions” – that is, where (as here) the safety and security of prosecutors and their families are targeted based on prosecutors’ actions in the line of duty.[lii]
The New York City Bar pays tribute to Rachelle Bergeron, who gave her young life for the rule of law. We call on the authorities in Yap to ensure that Ms. Bergeron’s assailants are brought to justice; and we call on governments everywhere to take all measures necessary to ensure that human rights defenders and lawyers generally – and prosecutors in particular – are able to fulfill their professional obligations free of “intimidation, hindrance, harassment, [or] improper interference” and without putting their physical safety and security at risk.
Standing with the people of Yap, we rededicate ourselves to the principles for which Ms. Bergeron stood every day. Her sacrifice will not be in vain.
Footnotes
[i] See generally, e.g., Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Former New York Lawyer Shot And Killed While Serving As Attorney General On Tiny Pacific Island (CBS New York, Oct. 16, 2019), https://newyork.cbslocal.com/2019/10/16/new-york-lawyer-shot-pacific-island/; Blayne Alexander, American prosecutor fatally gunned down in Pacific Nation of Micronesia (video) (NBC Nightly News with Lester Holt/Facebook, Oct. 15, 2019), https://www.facebook.com/watch/?v=399916230677507; Adeel Hassan, American Prosecutor Is Fatally Shot in Micronesia After Her Daily Run (New York Times, Oct. 16, 2019), https://nyti.ms/33y2yKM; Michael Strahan & Paula Faris, Murder Mystery in Paradise: FBI Steps in on Case of Slain American Lawyer (video) (ABC News/Good Morning America, Oct. 15, 2019), https://www.goodmorningamerica.com/news/video/american-lawyer-fatally-gunned-micronesia-66313339; Jasmine Aguilera, An American Prosecutor Has Been Shot Dead in Micronesia (Time, Oct. 16, 2019), https://time.com/5700680/us-prosecutor-shot-micronesia/; Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/; Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/.
[ii] State Gets New Assistant Attorney General (Yap State Government Briefs, Aug. 28, 2015), https://us9.campaign-archive.com/?u=9640342ddd234c5a7381e57a2&id=b7d08c4236&e=%5BUNIQID%5D&fbclid=IwAR3EgLxexeDCDtOyev2gYFKyvHJMKR_SoaftvSYxxAYnkQl914H0SD2GMpo; Adeel Hassan, American Prosecutor Is Fatally Shot in Micronesia After Her Daily Run (New York Times, Oct. 16, 2019), https://nyti.ms/33y2yKM; Lauren M. Johnson, US attorney working as a prosecutor in Micronesia killed outside her home (CNN, Oct. 15, 2019), https://www.cnn.com/2019/10/15/us/rachelle-bergeron-shot-and-killed-trnd/index.html.
[iii] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Yap State Gets New Assistant Attorney General (Yap State Government Briefs, Aug. 28, 2015), https://us9.campaign-archive.com/?u=9640342ddd234c5a7381e57a2&id=b7d08c4236&e=%5BUNIQID%5D&fbclid=IwAR3EgLxexeDCDtOyev2gYFKyvHJMKR_SoaftvSYxxAYnkQl914H0SD2GMpo; Rachelle Bergeron: 5 Fast Facts You Need to Know (Heavy, Oct. 15, 2019), https://heavy.com/news/2019/10/rachelle-bergeron/; Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/; Adeel Hassan, American Prosecutor Is Fatally Shot in Micronesia After Her Daily Run (New York Times, Oct. 16, 2019), https://nyti.ms/33y2yKM; Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/.
[iv] Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/.
[v] Yap State Gets New Assistant Attorney General (Yap State Government Briefs, Aug. 28, 2015), https://us9.campaign-archive.com/?u=9640342ddd234c5a7381e57a2&id=b7d08c4236&e=%5BUNIQID%5D&fbclid=IwAR3EgLxexeDCDtOyev2gYFKyvHJMKR_SoaftvSYxxAYnkQl914H0SD2GMpo; Nick Perry, Hundreds to Mourn American Prosecutor Slain in Micronesia (Daily Inter Lake/Associated Press, Oct. 22, 2019), https://www.dailyinterlake.com/article/20191021/AP/310219804.
[vi] Yap State Gets New Assistant Attorney General (Yap State Government Briefs, Aug. 28, 2015), https://us9.campaign-archive.com/?u=9640342ddd234c5a7381e57a2&id=b7d08c4236&e=%5BUNIQID%5D&fbclid=IwAR3EgLxexeDCDtOyev2gYFKyvHJMKR_SoaftvSYxxAYnkQl914H0SD2GMpo; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[vii] Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/; Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html.
[viii] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Adeel Hassan, American Prosecutor Is Fatally Shot in Micronesia After Her Daily Run (New York Times, Oct. 16, 2019), https://nyti.ms/33y2yKM; Hannah Kirby, Arrests made in the fatal shooting of a Waukesha native in Yap (Milwaukee Journal Sentinel, Oct. 29, 2019), https://www.jsonline.com/story/communities/waukesha/news/2019/10/29/arrests-made-in-killing-of-wisconsin-native-rachelle-bergeron-in-yap-micronesia/2498511001/; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[ix] Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Jill Sederstrom, American Attorney Gunned Down On Pacific Island Had ‘Most Dangerous Job’ There (Oxygen, Oct. 17, 2019), https://www.oxygen.com/crime-news/american-attorney-rachelle-bergeron-shot-in-micronesia-had-dangerous-job.
[x] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xi] Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/.
[xii] Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/.
[xiii] Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html; Jill Sederstrom, American Attorney Gunned Down On Pacific Island Had ‘Most Dangerous Job’ There (Oxygen, Oct. 17, 2019), https://www.oxygen.com/crime-news/american-attorney-rachelle-bergeron-shot-in-micronesia-had-dangerous-job.
[xiv] Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Jennifer Smith & Luke Kenton, Husband of slain American prosecutor who was shot dead in drive-by attack on tiny Micronesian island recalls her final moments and says she slept with a Machete under her pillow because she feared for her safety (Daily Mail, Oct. 17, 2019), https://www.dailymail.co.uk/news/article-7583805/Husband-prosecutor-murdered-tiny-Pacific-island-says-feared-life.html.
[xv] Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Jill Sederstrom, American Attorney Gunned Down On Pacific Island Had ‘Most Dangerous Job’ There (Oxygen, Oct. 17, 2019), https://www.oxygen.com/crime-news/american-attorney-rachelle-bergeron-shot-in-micronesia-had-dangerous-job.
[xvi] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xvii] Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xviii] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Adeel Hassan, American Prosecutor Is Fatally Shot in Micronesia After Her Daily Run (New York Times, Oct. 16, 2019), https://nyti.ms/33y2yKM; Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/.
[xix] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Adeel Hassan, American Prosecutor Is Fatally Shot in Micronesia After Her Daily Run (New York Times, Oct. 16, 2019), https://nyti.ms/33y2yKM; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Jasmine Aguilera, An American Prosecutor Has Been Shot Dead in Micronesia (Time, Oct. 16, 2019), https://time.com/5700680/us-prosecutor-shot-micronesia/; Richard Ewart, Rachelle Bergeron, Acting Attorney-General of Yap in Federated States of Micronesia, gunned down (Australian Broadcasting Corporation, Oct. 15, 2019), https://www.abc.net.au/news/2019-10-15/micronesia-yap-attorney-general-rachelle-bergeron-shot-dead/11604050; Isabel Vincent & Ebony Bowden, Murdered prosecutor Rachelle Bergeron was ‘target’ of dangerous enemies (New York Post, Oct. 19, 2019), https://nypost.com/2019/10/19/murdered-prosecutor-rachelle-bergeron-was-target-of-dangerous-enemies/.
[xx] Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xxi] Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html; Louella Losinio, Suspects named in Bergeron murder case (Pacific News Center, Oct. 31, 2019), https://pncguam.com/suspects-named-in-bergeron-murder-case/.
[xxii] Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html.
[xxiii] Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xxiv] Adeel Hassan, American Prosecutor Is Fatally Shot in Micronesia After Her Daily Run (New York Times, Oct. 16, 2019), https://nyti.ms/33y2yKM; Hannah Kirby, Arrests made in the fatal shooting of a Waukesha native in Yap (Milwaukee Journal Sentinel, Oct. 29, 2019), https://www.jsonline.com/story/communities/waukesha/news/2019/10/29/arrests-made-in-killing-of-wisconsin-native-rachelle-bergeron-in-yap-micronesia/2498511001/; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html.
[xxv] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Jennifer Smith & Luke Kenton, Husband of slain American prosecutor who was shot dead in drive-by attack on tiny Micronesian island recalls her final moments and says she slept with a Machete under her pillow because she feared for her safety (Daily Mail, Oct. 17, 2019), https://www.dailymail.co.uk/news/article-7583805/Husband-prosecutor-murdered-tiny-Pacific-island-says-feared-life.html; Jill Sederstrom, American Attorney Gunned Down On Pacific Island Had ‘Most Dangerous Job’ There (Oxygen, Oct. 17, 2019), https://www.oxygen.com/crime-news/american-attorney-rachelle-bergeron-shot-in-micronesia-had-dangerous-job.
[xxvi] Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Haidee Eugenio Gilbert, FBI to investigate slaying of American prosecutor in Micronesia (USA Today, Oct. 16, 2019), https://www.usatoday.com/story/news/nation/2019/10/16/rachelle-bergeron-fbi-probes-slaying-yap-micronesia-prosecutor/4005112002/.
[xxvii] Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Parents of Prosecutor Killed on Remote Island Will Take Her Body Home With Them (Inside Edition, Oct. 21, 2019), https://www.insideedition.com/parents-of-prosecutor-killed-on-remote-island-will-take-her-body-home-with-them-56805; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xxviii] Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xxix] Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Robert Michael Poole, The tiny island with human-sized money (BBC News, May 3, 2018), http://www.bbc.com/travel/story/20180502-the-tiny-island-with-human-sized-money.
[xxx] See, e.g., Public Statement by Gov. Henry S. Falan on Death of Acting AG (video) (Yap State Government Public Information Service, Oct. 15, 2019), https://www.facebook.com/YapStateGovNews/videos/469195077272110/?v=469195077272110; Louella Losinio, Yap Governor Falan: ‘Yap’s spirit is broken by this senseless and heinous act’ (Pacific News Center, Oct. 16, 2019), https://pncguam.com/yap-governor-falan-yaps-spirit-is-broken-by-this-senseless-and-heinous-act/; Governor of Yap, Updates on Acting Attorney General (Office of the Governor of Yap, Oct. 21, 2019, Oct. 25, 2019, & Oct. 28, 2019), http://www.yapstategov.org/aagupdates.html#; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/.
[xxxi] Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests; Nick Perry, Hundreds to mourn American prosecutor slain in Micronesia (Associated Press, Oct. 22, 2019),
https://apnews.com/b3a312ee767641b7a6c74c26bd66514f.
[xxxii] Nick Perry, Hundreds to mourn American prosecutor slain in Micronesia (Associated Press, Oct. 22, 2019), https://apnews.com/b3a312ee767641b7a6c74c26bd66514f; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html.
[xxxiii] Nick Perry, Hundreds to mourn American prosecutor slain in Micronesia (Associated Press, Oct. 22, 2019), https://apnews.com/b3a312ee767641b7a6c74c26bd66514f; Travis Fedschun & Associated Press, Arrests made after American lawyer serving as Micronesia’s assistant AG shot dead returning home from run (Fox News, Oct. 28, 2019), https://www.foxnews.com/world/american-lawyer-micronesia-killed-arrests.
[xxxiv] Hannah Kirby, Arrests made in the fatal shooting of a Waukesha native in Yap (Milwaukee Journal Sentinel, Oct. 29, 2019), https://www.jsonline.com/story/communities/waukesha/news/2019/10/29/arrests-made-in-killing-of-wisconsin-native-rachelle-bergeron-in-yap-micronesia/2498511001/; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/.
[xxxv] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Hannah Kirby, Arrests made in the fatal shooting of a Waukesha native in Yap (Milwaukee Journal Sentinel, Oct. 29, 2019), https://www.jsonline.com/story/communities/waukesha/news/2019/10/29/arrests-made-in-killing-of-wisconsin-native-rachelle-bergeron-in-yap-micronesia/2498511001/; Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html.
[xxxvi] Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 1, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/.
[xxxvii] Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html; Isabel Vincent, Suspect charged with Rachelle Bergeron’s murder was being investigated by her (New York Post, Nov. 2, 2019), https://nypost.com/2019/11/02/suspect-charged-with-rachelle-bergerons-murder-was-being-investigated-by-her/.
[xxxviii] Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html; Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html; Louella Losinio, Suspects named in Bergeron murder case (Pacific News Center, Oct. 31, 2019), https://pncguam.com/suspects-named-in-bergeron-murder-case/.
[xxxix] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Teo Armus, She fought for human rights on a tiny island that banned guns. Then she was shot dead. (Washington Post, Nov. 1, 2019), https://www.washingtonpost.com/nation/2019/11/01/she-fought-human-rights-tiny-island-that-banned-guns-then-she-was-shot-dead/; Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html.
[xl] Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html.
[xli] Alex J. Rhowuniong, Firearms are banned in Yap; no suspect yet in Bergeron murder (Pacific Island Times, Oct. 18, 2019), https://www.pacificislandtimes.com/single-post/2019/10/19/Firearms-are-banned-in-Yap-no-suspect-yet-in-Bergeron-murder; Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html.
[xlii] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019),
https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html; Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html.
[xliii] Murder in Yap: sleepy Pacific island rocked by shooting of American lawyer (The Guardian, Nov. 20, 2019), https://www.theguardian.com/world/2019/nov/21/in-yap-sleepy-pacific-island-rocked-by-shooting-of-american-lawyer; Isabel Vincent, Suspect charged with Rachelle Bergeron’s murder was being investigated by her (New York Post, Nov. 2, 2019), https://nypost.com/2019/11/02/suspect-charged-with-rachelle-bergerons-murder-was-being-investigated-by-her/; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html.
[xliv] Isabel Vincent, Suspect charged with Rachelle Bergeron’s murder was being investigated by her (New York Post, Nov. 2, 2019), https://nypost.com/2019/11/02/suspect-charged-with-rachelle-bergerons-murder-was-being-investigated-by-her/; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html.
[xlv] Isabel Vincent, Suspect charged with Rachelle Bergeron’s murder was being investigated by her (New York Post, Nov. 2, 2019), https://nypost.com/2019/11/02/suspect-charged-with-rachelle-bergerons-murder-was-being-investigated-by-her/; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html.
[xlvi] Nick Delgado, Suspect allegedly shot at Yap acting AG Bergeron 3 times (Guam Daily Post, Nov. 4, 2019), https://www.postguam.com/news/local/suspect-allegedly-shot-at-yap-acting-ag-bergeron-times/article_5a0d12a2-fbac-11e9-b85a-472b9e4e6756.html; Maxine Shen/Daily Mail & Lauren Fruen/Daily Mail & Associated Press, Revealed: Suspect charged with murder of American prosecutor shot dead on tiny Micronesian island was being investigated by her for ‘threatening someone with a gun’ (Daily Mail, Nov. 2, 2019), https://www.dailymail.co.uk/news/article-7643063/Suspect-charged-murder-American-prosecutor-island-Yap-investigated-her.html.
[xlvii] United Nations Basic Principles on the Role of Lawyers (adopted by the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, Aug. 27, 1990-Sept. 7, 1990), Principle 16, https://www.un.org/ruleoflaw/files/UNBasicPrinciplesontheRoleofLawyers.pdf.
[xlviii] U.N. Basic Principles on the Role of Lawyers, Principle 17, https://www.un.org/ruleoflaw/files/UNBasicPrinciplesontheRoleofLawyers.pdf.
[xlix] U.N. Basic Principles on the Role of Lawyers, Principle 18, https://www.un.org/ruleoflaw/files/UNBasicPrinciplesontheRoleofLawyers.pdf.
[l] United Nations Guidelines on the Role of Prosecutors (adopted by the Eighth U.N. Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, Aug. 27, 1990-Sept. 7, 1990), https://www.ohchr.org/Documents/ProfessionalInterest/prosecutors.pdf.
Above and beyond the U.N. Basic Principles on the Role of Lawyers and the U.N. Guidelines on the Role of Prosecutors, numerous provisions of the United Nations Declaration on Human Rights Defenders are to the same general effect. See generally United Nations Declaration on Human Rights Defenders (adopted by U.N. General Assembly Resolution A/RES/53/144, Dec. 9, 1998), https://www.ohchr.org/Documents/Issues/Defenders/Declaration/declaration.pdf.
[li] U.N. Guidelines on the Role of Prosecutors, Guideline 4, https://www.ohchr.org/Documents/ProfessionalInterest/prosecutors.pdf.
[lii] U.N. Guidelines on the Role of Prosecutors, Guideline 5, https://www.ohchr.org/Documents/ProfessionalInterest/prosecutors.pdf.
