Former Haitian Death Squad Leader Pleads Guilty to Fraud

Emanuel “Toto” Constant, the former leader of the Haitian paramilitary death squad known as FRAPH (the Revolutionary Front for Haitian Advancement and Progress), pled guilty on February 8, 2007 to grand larceny and fraud in conjunction with a real estate mortgage scheme.

Attorneys with the Center for Constitutional Rights (CCR) welcomed the news that he may finally do jail time, but expressed the desire to see him held accountable for his role in more than 5,000 murders and untold dismemberment, rapes and other torture and violence in the early 1990s.

"Emmanuel Constant deserves to serve a long sentence for what he did to the people of Haiti. If we can send him to jail for defrauding a bank, then so be it. It’s a start,” said Jennifer M. Green, Staff Attorney at the Center for Constitutional Rights.

For years, the Center for Constitutional Rights campaigned to have Constant held accountable for his crimes, from filing law suits to leading marches to his residence in Queens to working with grassroots groups in New York and Haiti to have him brought to justice. CCR, working with a coalition of Haitian and U.S. women’s organizations, went before the Organization of American States’ Inter-American Commission on Human Rights, which resulted in the condemnation of mass rape in Haiti by military and paramilitary forces including FRAPH.

Last fall, CCR, together with the Center for Justice and Accountability and the law firm of Sonnenschein, Nath & Rosenthal, won a $19 million civil judgment against Constant for crimes against humanity, attempted summary execution, and rape and other torture.

A former paid CIA informant, Constant has been permitted to live in the U.S. since 1996 despite his crimes. Following a violent military coup against democratically elected President Jean-Bertrand Aristide in 1991, FRAPH, under Constant's leadership, committed massacres, gang-rapes and other torture. Two of the three plaintiffs in the federal lawsuit were gang-raped in front of their families. A third was attacked by two FRAPH operatives and left for dead. After President Aristide returned to power, his government issued an arrest warrant for Constant, but Constant fled to the United States. Constant has been living in Queens since 1994.

In the mid-1990s, CCR obtained documents from the U.S. government through a series of Freedom of Information Act Requests which confirmed the broad and systematic pattern of FRAPH abuses and revealed that Constant directly conspired in the assassination of President Aristide's Minister of Justice, Guy Malary.


The Center for Constitutional Rights works with communities under threat to fight for justice and liberation through litigation, advocacy, and strategic communications. Since 1966, the Center for Constitutional Rights has taken on oppressive systems of power, including structural racism, gender oppression, economic inequity, and governmental overreach. Learn more at


Last modified 

October 23, 2007