More than three decades after the genocide against the Tutsi in Rwanda, when hundreds of thousands of people were killed in roughly one hundred days, the long pursuit of justice has not faded. It has shifted from the hills and roadblocks of Rwanda to courtrooms in Boston, Paris, The Hague, and Kigali, carried by survivors who refuse to let the world forget. In a Boston federal courtroom, a jury convicted Eric Tabaro Nshimiye, a 54-year-old Rwandan-born man who had been living in Ohio, of four counts of perjury and one count of obstruction of justice. The conviction did not come from a direct genocide charge, but from lies Nshimiye told while testifying at the 2019 trial of Jean Leonard Teganya, a former medical school colleague who was convicted of immigration fraud and perjury related to his own alleged role in the genocide. Prosecutors argued that Nshimiye lied to a federal jury to protect himself and Teganya, a fellow Rwandan accused of genocide-related crimes. In announcing the verdict, U.S. Attorney Leah B. Foley said Nshimiye had lived under a web of lies and deception, obtaining refuge in the United States by concealing his involvement in the genocide and the appalling acts he committed against the Tutsi community. “The United States protects victims, not violent criminals,” she said. “This verdict ensures Nshimiye can no longer hide behind his lies.” The case is one of many in recent years showing that accountability for genocide does not always arrive through a single dramatic trial. Sometimes it comes through immigration files, witness testimony, and the stubborn determination of people willing to tell the truth about the worst moments of their lives.
Nshimiye’s path to that courtroom began in 1994, as violence swept through Rwanda. He fled the country, traveled through Kenya, and entered the United States in 1995. He obtained refugee status and later became an American citizen. For nearly three decades, according to federal prosecutors, he kept his past hidden. He may have been a neighbor, a coworker, a citizen who seemed to belong to his new country. But witnesses who knew him in Rwanda told a different story. At the time of the genocide, Nshimiye was a medical student in Butare, a southern city that saw some of the most brutal violence. Witnesses testified that he took part in attacks against Tutsis, beating victims with a club and helping identify people at roadblocks where Tutsis were singled out and killed. Assistant Attorney General A. Tysen Duva said Nshimiye had concealed his involvement in the genocide and the heinous acts of violence he committed, including clubbing people to death. Then, Duva said, Nshimiye lied to immigration officials to become a citizen and lied to a federal jury to protect himself and a fellow perpetrator. Nshimiye’s defense team challenged the allegations, arguing that the stories were fabricated and that he was not in Butare when the violence began. The jury’s verdict did not resolve the question of whether Nshimiye personally participated in killings. It found that he lied under oath and obstructed justice. For survivors, the distinction may be less important than the fact that his deception was exposed. They traveled across the world to testify, returning in their memories to the most horrifying moments of their lives. Jeffrey Grimming, acting special agent in charge of HSI New England, said the verdict belonged to the victims who bravely shared their stories. “We are deeply grateful for their contribution and sacrifice,” he said. U.S. Senior District Judge F. Dennis Saylor IV scheduled sentencing for January 26, 2027.
The broader search for justice has its roots in the scale of the genocide. Organized by extremist political and military elements, the genocide against the Tutsi killed hundreds of thousands of people in approximately 100 days, leaving survivors, orphans, widows, and a society shattered by loss and betrayal. After the killing ended, millions of people fled, and the region was transformed. The International Criminal Tribunal for Rwanda was created to prosecute those most responsible, and over two decades it tried many senior political, military, and militia figures before closing in 2015. Its remaining functions were handed to the International Residual Mechanism for Criminal Tribunals, which kept responsibility for outstanding cases and for tracking fugitives. The closure of the tribunal did not mean the end of accountability. Some cases were transferred to national courts, and investigators continued to pursue suspects across Africa, Europe, and North America. One of the most significant arrests came in May 2023, when Fulgence Kayishema was captured in South Africa after more than twenty years as a fugitive. Kayishema, a former police officer, was accused of helping plan the killing of more than 2,000 Tutsi men, women, and children who had sought refuge in a church in western Rwanda in April 1994. The indictment alleged that he and others tried to burn the church, then used a bulldozer to bring it down, and later arranged for bodies to be moved to mass graves. These are allegations that have not been tested in court, but Human Rights Watch called his arrest an important milestone. Lewis Mudge, the organization’s Central Africa director, said at the time: “Kayishema’s arrest shows there is no expiration date on justice for the most serious crimes.”
But the passage of time has also brought frustration. Some suspects have died before they could face judgment. Félicien Kabuga, accused of helping finance and organize the genocide, was arrested in France in 2020 after more than two decades on the run. His trial before the IRMCT opened in September 2022 but was suspended while judges considered whether he was medically fit to stand trial. Augustin Bizimana, Rwanda’s defense minister during the genocide, was confirmed dead in 2020 after his remains were identified in the Republic of Congo. Protais Mpiranya, who commanded the presidential guard during the genocide, was confirmed dead in 2022. Another fugitive, Phénéas Munyarugarama, died in the Democratic Republic of Congo in 2002, though his death was confirmed later. For survivors and relatives of victims, these deaths close the door on the possibility of a courtroom reckoning. They also illustrate the practical difficulties of international justice. Suspects can remain at large for decades, moving across borders and living under false identities. Evidence grows cold. Witnesses die. Proceedings become tangled in questions of health, jurisdiction, and whether an accused person can be safely transferred to another country. The Kayishema case itself shows the gap between arrest and trial. His case was referred to Rwandan authorities in 2012, but he was not arrested until 2023. After his capture, legal proceedings moved through South African courts and the international mechanism, with the question of transfer to Rwanda still part of the process. None of this is neat. Justice in the aftermath of atrocity rarely is.
The question of where suspects should be tried has been equally difficult. Human Rights Watch has argued that trials close to victims and affected communities can strengthen accountability, but it has also raised concerns about Rwanda’s justice system, including judicial independence and possible political interference in sensitive cases. In 2008, the organization opposed the transfer of Kayishema’s case to Rwanda, saying fair-trial guarantees could not be assured. It has documented concerns in other cases transferred to Rwandan courts. Ladislas Ntaganzwa, a former mayor whose case was transferred to Rwanda, was convicted of genocide and related crimes in 2020 and sentenced to life imprisonment. His conviction was upheld on appeal in 2023, but monitoring of his proceedings raised questions about detention conditions, access to defense lawyers, and the protection of confidential legal material. The case of Paul Rusesabagina, whose 2021 conviction in Rwanda followed a controversial arrest and transfer to the country, also drew international scrutiny over due process and the treatment of government critics. His sentence was commuted by presidential order in 2023. These concerns do not mean that genocide suspects should not be prosecuted. Rather, they underline the importance of ensuring that proceedings meet international standards: a fair and public hearing, access to legal representation, and a judiciary that is genuinely independent. The International Residual Mechanism retains the power to monitor cases referred to national jurisdictions and can revoke a referral if it determines that the accused will not receive a fair trial. For international justice institutions, the challenge is therefore twofold. They must pursue alleged perpetrators relentlessly, but they must also protect the rights of the accused. If trials are seen as politically controlled or unfair, the credibility of the entire project suffers.
Nshimiye’s conviction is not the same as a finding that he personally committed the mass killings. It is a finding that he lied to a federal jury and tried to obstruct justice, and in that sense it is a narrower kind of accountability. But it is also part of a wider effort to establish the truth about what happened in Rwanda in 1994. Immigration proceedings, witness testimony, and perjury prosecutions have become unexpected tools in that effort. A person who spent decades hiding behind a false story can be exposed not only through war crimes investigations but through the ordinary machinery of law: visas, citizenship applications, courtroom oaths. For East Africa, these cases also carry a deeper meaning. Kenya and other neighboring countries were destinations for people displaced by the violence. The Democratic Republic of Congo became a refuge for some fugitives. The genocide’s aftermath reshaped the entire region, creating new conflicts and population movements that continue to affect the Great Lakes. The enduring challenge is to ensure that the passage of time, movement across borders, or the closure of an international tribunal does not automatically end the prospect of accountability. But the deaths of suspects before trial, the difficulty of gathering evidence, and disputes over fair-trial safeguards all show that arrest alone cannot deliver justice. Ultimately, the legitimacy of the process depends not only on whether suspects are found, but on whether courts establish responsibility through credible proceedings that respect the rights of victims and defendants alike. For the survivors who testified against Nshimiye, the verdict may not bring closure. Nothing can bring back the people they lost. But it does say that the past was not forgotten, that lies told to protect perpetrators can be unraveled, and that the search for justice, however slow and imperfect, remains alive.