coup overthrew the government). Analysis has revealed longstanding U.S. support for the Guatemala military through its years of state terrorism and civil war. Prosecution of her case Sister Dianna filed a case with the Inter-American Commission on Human Rights in 1990 based on her abduction and torture by agents of the Guatemalan government in 1989. The commission ruled in 1997 that the state of Guatemala had violated Articles 1, 5, 7, 8, 11, 12, 16 and 25 of the American Convention on Human Rights. It found that Ortiz had been placed under surveillance, was threatened, then kidnapped and tortured. It made a judgment against the state of Guatemala, with remedies suggested. It noted that a domestic case had quickly been filed with the National Police in the department where the sisters were working, and that Ortiz had cooperated with the investigation, but in six years the government had made no progress on it. The commission noted that high-ranking officials of the National Police, Ministry of Interior and Ministry of Defense had immediately denied Ortiz's statement and tried to denigrate her account before any investigation was done. Given the difficulty of victims prosecuting torture and human rights cases, including murders, under military dictatorships, plaintiffs have begun to pursue civil suits. The first were filed under the Alien Tort Claims Act (ATCA), which had been passed soon after the American Revolutionary War to deal with commercial issues. In the late twentieth century, this law began to be used in human rights cases. Trying to enable victims' seeking justice after not being able to gain it in countries that used torture, Congress passed the Torture Victim Protection Act (1992). Ortiz was the first to file a suit under this law, arguing that it was retroactive to the time of her torture. The court agreed, saying "torture had been universally condemned prior to Ortiz's ordeal." The civil case of Ortiz was combined by her legal representative, the Center for Constitutional Rights, with Xuncax v. Gramajo, in which eight Kanjobal Indians had filed a U.S. civil suit against General Héctor Gramajo, Minister of Defense in Guatemala (1987-1990) under the Alien Tort Claims Act (ATCA). They contended that he had command responsibility for the genocide against the Maya, which resulted in the deaths of most people in their village, as well as responsibility for other abuses. Their case was heard in federal court in Massachusetts in