thesis of the French film Death Squadrons: The French School by Monique Robin. The French had themselves developed practices in defence of its declining empire through the 20th century, setting up torture "universities" at Poulo Condor (now Côn Sơn) – an island off Vietnam (then French Indo-China, subsequently taken over by the United States) and at Philippeville (now Skikda) in Algeria. Police abuse remains a reality in France today, while France has been condemned by the European Court of Human Rights (ECHR) for the conditions of detention in prisons, including the use of torture on detainees. Although the law and the Constitution prohibits any kind of torture, such practices happen. In 2004, the Inspector General of the National Police received 469 registered complaints about illegitimate police violence during the first 11 months of the year, down from 500 during the same period in 2003. There were 59 confirmed cases of police violence, compared to 65 in the previous year. In April 2004, the ECHR condemned the government for "inhumane and degrading treatments" in the 1997 case of a teenager beaten while in police custody. The court ordered the government to pay Giovanni Rivas $20,500 (15,000 euros) in damages and $13,500 (10,000 euros) in court costs. The head of the police station in Saint-Denis, near Paris, has been forced to resign after allegations of rape and other violence committed by the police force under his orders. Nine investigations concerning police abuse in this police station were carried out in 2005 by the IGS inspection of police. These repeated abuses are said to be one of the causes of the 2005 civil unrest. Conditions in detention centers for illegal aliens have also been widely criticized by human rights NGOs. In 2006 a 20-year-old Serbian woman accused a policeman of attempting to rape her in such a centre in Bobigny, in the suburbs of Paris, the year before. Guatemala During the Guatemalan civil war and the repression by the army against civilians and suspected opponents of the military dictatorship, murder (even genocide), torture, rape and inhumane and degrading treatment was systematically used by the Guatemalan armed forces and police. There is evidence that the CIA, in anticommunist campaigns during the 1980s, was involved in these tortures (in Latin America the threat of communism was often used as justification for dictatorship during the Cold War). Thousands of victims were tortured and murdered. For example,