Closing the ‘Remedy Gap’- The Limits and Promise of Diplomatic Protection for Victims of the Cholera Epidemic in Haiti

Abstract

Haitian people are all too familiar with courts expressing sympathy for their plight but ultimately closing the courtroom doors to them. In Sale v. Haitian Centers Council, the Supreme Court concluded its opinion denying relief by quoting the approval from Judge Edwards: 'Although the human crisis is compelling, there is no solution to be found in a judicial remedy.' That need not be the case here.'