combination with Ortiz v. Gramajo, which was decided under the Torture Victim Protection Act (1992), the first to make use of the new law. The Center for Constitutional Rights filed against Gramajo when he was in Massachusetts doing graduate work at the Harvard Kennedy School of Government. The ATCA "allows Americans and foreigners to file suit for violations of international law while the defendant is in the United States". The court agreed with the plaintiffs on Gramajo's responsibility, saying the former general "devised and directed the implementation of an indiscriminate campaign of terror against civilians", including the nine plaintiffs. The judge ordered Gramajo to pay each of the Guatemalans $1 to $9 million each, and Ortiz $5 million. The general said he had no money. Later that year, he was barred from future entry into the U.S. under immigration laws. "The Xuncax court also added summary execution or extrajudicial execution and arbitrary detention (as differentiated from prolonged arbitrary detention) to the list of torts cognizable under the ATCA. "Numerous other cases have now reaffirmed the responsibility and civil liability of commanders and those in authority for the actions of their troops and subordinates." In its ruling, the judiciary said that "[Gramajo-Morales] ... was aware of and supported widespread acts of brutality committed under his command resulting in thousands of civilian deaths." Ortiz recounted her experience in formal testimony several times. Raul Molina Mejía in his article, "The Struggle against Impunity in Guatemala", Journal of Social Justice, vol. 26 (1999), describes Ortiz's abduction and treatment as an example of state-sponsored terrorism based on impunity. He writes: "impunity as concrete legal or 'de facto' actions taken by powerful sectors to prevent investigation or prosecution, such as amnesty laws, pardons, thwarting investigations, the hiding of documents, and tampering with legal samples were abundant in Guatemala." He also notes the unsolved killing of Michael DeVine, the El Aguacate massacre, and the 1990 surge of killings at the National University of San Carlos. Molina Mejía writes that the "political/psychological" aspect of this impunity, is "a dimension resulting from state terrorism, by which political options in a polity are restricted and controlled through the state's manipulation of fear". Human rights work In 1994, Dianna Ortiz began working at the Guatemala Human Rights Commission/USA (GHRC). GHRC's director, Sister Alice Zachmann, had advocated for her release from clandestine detention in 1989 and had invited Dianna to give the