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Guillaume Kigbafori Soro and Others v. Rep. of Côte d'Ivoire (Afr. Ct. H.P.R.)

Published online by Cambridge University Press:  28 October 2020

Marie Joseph Ayissi
Marie Joseph Ayissi*
Affiliation:
Marie Joseph Ayissi, Human Rights Officer, Office of the United Nations High Commissioner for Human Rights at Geneva. The views expressed in the present introductory note are personal and do not necessarily reflect those of the United Nations.
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Extract

On April 22, 2020, the African Court on Human and Peoples’ Rights (the Court) rendered an order for provisional measures in the case Guillaume Kigbafori Soro and Others v. Côte d'Ivoire. In this decision, the Court found that the situation of the applicants who were facing criminal proceedings domestically was sufficiently urgent and grave to ask Côte d'Ivoire to halt the execution of the arrest and detention warrants issued against them, with a view to preserving their rights and avoiding irreparable harm against them.

Information

Type
International Legal Documents
Information
International Legal Materials , Volume 59 , Issue 6 , December 2020, pp. 1013 - 1022
Copyright
Copyright © American Society of International Law 2020

Introduction

On April 22, 2020, the African Court on Human and Peoples’ Rights (the Court) rendered an order for provisional measures in the case Guillaume Kigbafori Soro and Others v. Côte d'Ivoire. In this decision, the Court found that the situation of the applicants who were facing criminal proceedings domestically was sufficiently urgent and grave to ask Côte d'Ivoire to halt the execution of the arrest and detention warrants issued against them, with a view to preserving their rights and avoiding irreparable harm against them.

Background

The case originated with a direct application before the Court by Guillaume K. Soro, a former Prime Minister and Speaker of the National Assembly, and nineteen other applicants. They claimed that by issuing arrest and detention warrants against Guillaume K. Soro and the nineteen others—already executed as placement in detention—Côte d'Ivoire violated their rights under the African Charter on Human and Peoples’ Rights (the Charter) in Articles 7, 12, and 18,Footnote 1 as well as under Articles 14 and 23Footnote 2 of the International Covenant on Civil and Political Rights (ICCPR).

Together with their application on the merits, they requested the Court to order provisional measures aimed at preserving their rights by halting the execution of the arrest warrant against Guillaume K. Soro and suspending the execution of the arrest and detention warrants against the nineteen other applicants, and releasing them or allowing them to fully enjoy their political and civil rights pending the Court's judgment.Footnote 3

The application was prompted by criminal proceedings initiated on December 20, 2019, by domestic judicial authorities against Guillaume K. Soro and four other applicants, for embezzlement of public funds, while the other applicants were accused of complicity and participation in a plan to overthrow the government and destabilize the country. As a result, judicial authorities issued an arrest warrant against Guillaume K. Soro and arrested, placed in detention, and prosecuted the other applicants. Upon request by the State Prosecutor of the Court of first instance of Abidjan Plateau, the Cassation Court appointed an investigating judge to the case, after which the applicants seized the Court.

To decide on provisional measures, the Court first ascertained its prima facie ratione materiae and ratione personae jurisdiction and examined the objection raised by Côte d'Ivoire to the admissibility of the application. It then examined whether the criteria of extreme gravity, urgency, and the prevention of an irreparable harm were met.

The Court's Order

The Court began by reaffirming its well-established jurisprudence that only the prima facie jurisdiction is requirement in case of a request for provisional measures.Footnote 4 As such, the Court found that it had prima facie jurisdiction, as Côte d'Ivoire was party to the Charter and the ICCPR, and the rights invoked by the applicants were covered by these two instruments. It rejected Côte d'Ivoire's objection to the admissibility of the application on the grounds of non-exhaustion of local remedies.

As for the criteria of extreme gravity, the Court recalled that it “presupposes a real ‘risk and it is imminent that irreparable harm could take place before the Court renders its final judgment’ in the matter,” while urgency refers to situations where “acts which may cause irreparable harm could take place at any time before the Court renders its judgment in the matter.”Footnote 5

Côte d'Ivoire unsuccessfully contended that the three criteria of extreme gravity, urgency, and irreparable harm were not met, that evidence supporting the applicants’ fears was not adduced, and that the request submitted was beyond the scope of provisional measures and risked impeding the normal course of the domestic justice system. Taking into account a number of factors, in particular the potential prison terms faced by the twenty applicants, the ongoing execution of the arrest and detention warrants against the applicants (including the declared candidate to the elections, Guillaume K. Soro), and the proximity of the upcoming elections, the Court concluded that there was a situation of extreme urgency and gravity so as not to compromise the freedom and political rights of the applicants.

The Court further found that the arrest and detention warrants against the applicants were unnecessary in the domestic proceedings and considered that suspending the detention order during the domestic judicial investigation would preserve the rights of the applicants and also prevent serious and irreparable consequences. The Court considered that it was necessary to stay the execution of the arrest and detention warrants and to maintain the status quo ante until it rendered its judgment on the merits.Footnote 6

It ordered Côte d'Ivoire to halt the execution of the arrest warrant against Guillaume K. Soro and to suspend the execution of the detention warrants against other applicants. It also requested Côte d'Ivoire to report on the implementation of the provisional measures within thirty days, as from the date of notification of the Order.Footnote 7

After the Court had issued its Order, Côte d'Ivoire sentenced Guillaume K. Soro to twenty years of imprisonment and barred him from civic duties for five years,Footnote 8 thus disregarding the measures ordered by the Court.

Conclusion

The decision of the Court is of particular interest in many aspects. First, the Court has proved consistency in its well-established jurisprudence with regard to its prima facie jurisdiction in the cases requesting provisional measures. Second, the order seemed to confirm a trend in the Court's jurisprudence concerning the protection of the right to participate in the state's political and public affairs. In the present case, the Court considered as a risk of irreparable harm the fact that the applicants may be deprived of their rights to participate in an election, particularly in view of the fact that one of them was due to stand for a presidential election.

After the order was issued, Côte d'Ivoire withdrew its declaration made on June 11, 2013, under Article 34(6) of the Protocol to the Charter, which permits individuals and non-governmental organizations to directly access the Court. Although Côte d'Ivoire did not explicitly explain the motives of its withdrawal, it was notified on April 28, 2020, a week after the Court rendered its Order.Footnote 9 This withdrawal took place in a the context where other states parties,Footnote 10 namely Benin on March 24, 2020, Tanzania on November 14, 2019, and Rwanda on February 24, 2016, also withdrew their Article 34(6) declarations, criticizing the Court's “behaviour” and accusing it of being too intrusive into areas of sovereignty.Footnote 11

Although the Court's order relates to provisional measures, it nevertheless consolidates its jurisprudence with regard to the right of individuals to participate freely in their state's political and public affairs, including the right to stand for an election, and the importance of safeguarding such a right.Footnote 12 Although it appears that the Order led to the withdrawal of Côte d'Ivoire's Article 34(6) declaration, the Court nevertheless sent a message regarding its determination to uphold and protect human rights as enshrined in the Charter, including when domestic proceedings are ongoing. In that sense, the Court's Order remains significant despite some criticism about its lack of pragmatism and a concern that it will weaken its authority, and despite the risk of further disengagement from the Court by other states.Footnote 13

GUILLAUME KIGBAFORI SORO AND OTHERS V. REPUBLIC OF CÔTE D'IVOIRE (AFR. CT. H.P.R.)

This text was reproduced and reformatted from the text available at the African Court on Human and Peoples' Rights website (visited August 26, 2020), https://en.african-court.org/images/Cases/RulingOnJurisdiction/012-2020--Guillaume-Soro-v-Republic-of-Cote-divoire---Order-for-provisional-measures.pdf.

The Court composed of: Ben KIOKO, Vice-President, Rafaâ BEN ACHOUR, Angelo V. MATUSSE, Suzanne MENGUE, M-Thérése MUKAMULISA, Tujilane R. CHIZUMILA, Chafika BENSAOULA, Blaise TCHIKAYA, Stella I. ANUKAM and Imani D. ABOUD, Judges and Robert ENO, Registrar.

Pursuant to Article 22 of the Protocol to the African Charter on Human and Peoples' Rights on the Establishment of an African Court on Human and Peoples' Rights (hereinafter “the Protocol”) and Rule 8 (2) of the Rules of Court (hereinafter “the Rules”), Judge Sylvain ORE, an Ivorian national, recused himself.

In the Matter of.

GUILLAUME KIGBAFORI SORO AND OTHERS

Represented by.

  1. i. Mr. Affoussy BAMBA, Advocate of the Paris Bar;

  2. ii. Mr. Brahima SORO, Advocate of the Abidjan Bar;

versus

THE REPUBLIC OF COTE D'IVOIRE

Represented by.

  1. i. Mr. Constant Zirignon DELBE, Technical Advisor to the Minister of Justice and Human Rights, keeper of the seals;

  2. ii. Barrister Abdoulaye Meite, Advocate of the Cote d'Ivoire Bar;

  3. iii. Barrister Samassi Mamadou, Advocate of the Cote d'Ivoire Bar;

  4. iv. Barrister Patrice Gueu, Advocate of the Céte d'lvoire Bar;

  5. v. Barrister Mamadou Kone, Advocate of the Céte d'Ivoire Bar.

After deliberating,

Renders the following Order:

I. THE PARTIES

1. Guillaume Kigbafori SORO, Alain LOGOGNON, Camara LOUKIMANE, Kanigui SORO, Yao SOUMAILA, Soumahoro KANDO, Kamaraté Souleymane KONE, Karidioula Souleymane, Tehfour KONE, Simon SORO, Porlo Rigobert SORO, Félicien SEKONGO, Marc Kidou OUATTARA, Mamadou DJIBO, Aboubacar TOURE, Babou TRAORE, Ladji OUATTARA, Gnamiand N'DRIN, Dahafolo KONE, Adama ZEBRET (hereinafter referred to as “the Applicants”) are nationals, politicians and Parliamentarians from Cote d'Ivoire, some of whom have held senior positions in government amongst which, Prime Minister and Head of Government, Speaker of the National Assembly, ministers or Heads of Political Parties. An arrest and detention warrants were issued against them in a criminal matter relating to embezzlement of public funds and theft of public property and of plotting against the authority of the State. They were indicted on 20 December 2019.

2. The application was filed against the Republic of Cote d'Ivoire (hereinafter referred to as “the Respondent State”) which became a party to the African Charter on Human and Peoples' Rights (hereinafter referred to as “the Charter”), on 31 March 1992 and to the Protocol on 25 January 2004. The Respondent State also deposited the Declaration under Article 34 (6) of the Protocol, on 23 July 2013, thereby accepting the jurisdiction of the Court to receive applications from individuals and non-governmental organizations.

II. SUBJECT OF THE APPLICATION

A. Facts of the matter

3. It emerges from the application that on 20 December 2019, the State Prosecutor in the Court of First Instance of Abidjan Plateau was seized of a complaint filed by the Treasury Solicitor against Cissé Mory and René N. N'guessan, Kamaraté Souleymane Kone and Guillaume Kigbafori Soro concerning embezzlement of public funds committed in 2007, when Guillaume Kigbafori Soro held the post of Prime Minister. The other Applicants are accused of complicity and participating in a plan to overthrow the government and destabilise the country.

4. Three days later, that is, on 23 December 2019, the State Prosecutor gave a press conference and announced that the Directorate for territorial surveillance informed him that Guillaume Kigbafori Soro, who had travelled abroad for several months “planned to overthrow the government and take control of the country”.

5. An arrest warrant was issued against Guillaume Kigbafori Soro while between 23 and 24 December 2019, the other Applicants were arrested, prosecuted for embezzlement of public funds, money laundering, funding terrorism, complicity and acts of serious suspicion of an attempt to attack the authority and integrity of the country and placed under custody in different detention centres in Abidjan and other cities in the Country.

6. On 8 January 2020, the State Prosecutor seized the Cassation Court requesting the latter to appoint a Judge to conduct all necessary investigations relating to the case. By a Ruling of 17 January 2020, the Cassation Court granted the request by appointing a judge to conduct the investigation. It was within this context that the Applicants seized this Court of an application for violation of their human rights as well as a request for provisional measures.

B. Alleged Violations

7. In their application on the merits, the Applicants allege that their rights guaranteed under Articles 7, 12 and 18 of the Charter and Articles 14 and 23 of the International Covenant on Civil and Political Rights (ICCPR), have been violated. They specified the violation of the following rights:

  1. i. The right to fair trial;

  2. ii. The right to be tried by a competent tribunal;

  3. iii. The right to presumption of innocence;

  4. iv. The right to defence;

  5. v. The right to be informed about charges brought against them and the right to free access to the case file;

  6. vi. The right to freedom and security;

  7. vii. The freedom of movement of Mr. Guillaume Kigbafori Soro;

  8. viii. The right of equality of all before the law and equal protection of the law; and

  9. ix. The right to the moral health of the family.

III. SUMMARY OF THE PROCEDURE BEFORE THE COURT

8. On 2 March 2020, the main application and the request for provisional measures, were both filed at the Registry of the Court.

9. On 12 March 2020, the Registry acknowledged receipt of both the application and the request for provisional measures and notified the Respondent State on the same day. By the same notification, the Registry requested the Respondent State to file its submission on the request for provisional measures.

10. On 25 March 2020, the Respondent State filed its submission on the request for provisional measures.

11. On 9 April 2020, one of the Applicants, Alain Lobognon seized the Court with a request for provisional measures aimed at securing his immediate release on bail. He argued that since his detention, his health situation had deteriorated considerably and that the prison officials deliberately kept his family away and prevented them from seeing him.

12. On 12 April 2020, the Registry acknowledged receipt of the said request and served it on the Respondent State.

Prayers of the APPLICANTS

13. The Applicants pray the Court to:

  1. i. “i. Stay the execution of the arrest warrant against Guillaume Kigbafori Soro;

  2. ii. Suspend the execution of the arrest and detention warrants against other Applicants and to release them or allow them to fully enjoy their political and civil rights pending the judgment of the Court on the merits.

  3. iii. Report to the Court within 15 days as from the day of reception of the order for provisional measures on the implementation of the order”

IV. THE JURISDICTION OF THE COURT

14. The Applicants invoke Articles 3 and 5(3) of the Protocol to contend that, since their application infers the violation of provisions of the Charter and since it is against the Respondent State which has made the Declaration under Article 34(6) of the Protocol, the Court should, without ascertaining whether it has jurisdiction on the merits of the case issue the provisional measures sought based on its prima facie jurisdiction.

15. The Respondent State did not submit on this issue.

***

16. Pursuant to Article 3(1) of the Protocol “the jurisdiction of the Court shall extend to all cases and disputes submitted to it concerning the interpretation and application of the Charter, this Protocol and any other relevant human rights instruments ratified by the State concerned”.

17. When seized with an application, the Court is required to conduct a preliminary examination of its jurisdiction pursuant to Articles 3 and 5(3) of the Protocol. However, with regard to provisional measures, the Court need not ascertain whether or not it has jurisdiction on the merits of the case, but simply has to ensure that it has prima facie Footnote 1 jurisdiction.

18. In the instant case, the rights alleged by the Applicants to have been violated, are rights protected under the African Charter and the International Covenant on Civil and Political Rights (ICCPR), two human rights instruments to which the Respondent State is a party.Footnote 2

19. Based on the foregoing, the Court finds that it has prima facie jurisdiction to hear the application.

V. ADMISSIBILITY

20. The Respondent State contends that one of the Applicants, Guillaume Kigbafori Soro has not exhausted available local remedies, notably the remedy against the order of the investigating Judge who exercised his mandate to investigate the matter. It further contends that as regards the other Applicants, they too failed to exhaust the remedy to challenge their remand in custody as provided under Article 220 of the Ivorian Criminal Procedure Code.

21. The Applicants refute this averment by the Respondent State and submit records of declaration of appeal filed by the 15 Applicants against the Order remanding them in custody, for an assessment by the Court.

***

22. The Court underscores that in regard to provisional measures, neither the Charter nor the Protocol provide conditions for admissibility. Consideration of requests for provisional measures is only subject to one condition, that of determining the prima facie jurisdiction of the Court, which has been established in the instant case.

23. Consequently, the Court dismisses the objection raised by the respondent State and will therefore consider the provisional measures sought.

VI. PROVISIONAL MEASURES SOUGHT

24. The Applicants contend that issuing an arrest warrant against Guillaume Kigbafori Soro exposed him to arrest and extradition to his country where he could be detained, and this would prevent him not only from campaigning for the next presidential election of October 2020 for which he intends to stand as a candidate but he also runs the risk of being disqualified for the election. They are of the view that an arrest and detention of Guillaume Kigbafori Soro in such a context will seriously impact on his political rights.

25. As regards the other Applicants, they allege that their illegal and arbitrary detention, regardless of their immunity forced them to stop their political activities and further prevented them from enjoying their freedom of expression. They aver that this is a situation of extreme gravity and urgency and the risk of irreparable harm to them, in particular their right to life and physical integrity as enshrined in the Charter.

26. The Applicants contend that the urgency and gravity of the situation required provisional measures to safeguard their political and parliamentary rights and their freedom which had been trampled upon.

*

27. The Respondent State contends that the conditions set out for the Court to issue provisional measures, notably, extreme gravity, urgency and the prevention of irreparable harm to persons have not been met and that the application does not have any probative value to warrant such measures. It affirms that the Applicants failed to adduce any material evidence in support of their fears based on eventualities and nothing else but speculation and suspicion.

28. The Respondent State contends that the detention orders against the Applicants, with the exception of Guillaume Kigbafori Soro, have already been implemented and those concerned are not in a position to call for the suspension.

29. According to the Respondent State the provisional measures sought go far beyond the scope of provisional measures and could impede the normal functioning of the justice system. In that regard, it prays the Court to dismiss the request for provisional measures filed by the Applicants.

***

30. The Court notes that Article 27(2) of the Protocol provides as follows: “In case of extreme gravity and urgency and when necessary to avoid irreparable harm to persons, the Court shall adopt such provisional measures as it deems necessary”.

31. Rule 51(1) of the Rules of Court, however, provides that: “Pursuant to article 27(2) of the Protocol, the Court may, at the request of a party, the Commission or on its own accord, prescribe to the parties any interim measure which it deems necessary to adopt in the interest of the parties or of justice.”

32. The Court notes that it behoves on it to decide in each case, whether in light of the specific circumstances of the case, it has to exercise the jurisdiction conferred on it under the above-mentioned provisions.

33. The Court takes into account the applicable criteria when dealing with provisional measures, which are of a specific nature and can only be ordered in cases of extreme gravity, urgency and to prevent irreparable harm when all these conditions are met.Footnote 3 In that regard, the Court notes that extreme gravity presupposes that there is a real “risk and it is imminent that irreparable harm could take place before the Court renders its final judgement” in the matter and there is urgency each time “acts which may cause irreparable harm could take place at any time before the Court renders its final decision in the matters” in question.Footnote 4

34. In the instant case, the Court notes that the Applicants constitute twenty “personalities”, a former Prime Minister and Head of Government, a former Speaker of the House of Assembly, former Ministers, current parliamentarians, a Police Commissioner, a Doctor and leaders of political parties, accused of embezzling public funds, of attempting to embezzle public funds, money laundering, funding terrorism, complicity and presumption of serious attempts to overthrow the authority and integrity of the State. The Applicants are facing prison terms ranging from 20-years to life imprisonment as provided under Articles 162 and 163 of the Ivorian penal code.

35. The Court further notes that in the instant case, the execution of the arrest or detention warrant against political personalities amongst whom is one who has already declared his intention to stand for elections and the fact that the elections are just a few months away, could seriously compromise the freedom and political rights of the Applicants. To that end, the Court notes that this is a situation of extreme urgency since the said elections are scheduled to take place less than six months from the date of this application.

36. The Court also notes that it is a principle that arrest or detention warrants are taken for serious acts as a protective measure or when the accused do not offer enough guarantees to appear before national courts. In the present case, the Court considers that, with the applicants' social and professional situation, they have well-known addresses.

37. The Court also recalls that in criminal matters, considering that the accused enjoys the benefit of doubt and the presumption of innocence, the suspension of the detention order against the Applicants during investigation is a measure which will not only preserve the rights of everyone but would also prevent serious and irreparable consequences.Footnote 5

38. The Court notes that the situation in which the Applicants find themselves exposes them to a serious risk of being deprived of the enjoyment of their rights and this is a situation where the unexpected circumstances may lead to irreparable harm. The Court also finds that, in the present state of proceedings against the Applicants, it is necessary to stay the execution of the arrest and detention warrants and to maintain the status quo ante until it renders its judgment on the merits.

39. Accordingly, the Court finds that the circumstances in this case require it to order provisional measures pursuant to Article 27(2) of the Protocol and Rule 51 of the Rules of Court, to preserve the status quo ante pending the judgement on the merits of the case

40. Regarding the request filed on 9 April 2020 by the Applicant, Alain Logbonon, the Court is of the view that it is not necessary to consider his request for provisional measures in a separate order since the allegations of the rights of the Applicant to adequate healthcare and to be visited by members of his family are adequately addressed by the present order of the Court.

41. To avoid any ambiguity, this Order is on provisional measures and does not in any way prejudge the findings of the Court on jurisdiction, admissibility and the merits of the main application.

VII. OPERATIVE PART

42. For these reasons,

THE COURT,

Unanimously,

Orders the Respondent State to:

  1. i. stay the execution of the arrest warrant against Guillaume Kigbafori Soro;

  2. ii. stay the execution of the detention warrants against the Applicants Guillaume Kigbafori SORO, Alain LOGOGNON, Camara LOUKIMANE, Kanigui SORO, Yao SOUMAILA, Soumahoro KANDO, Kamaraté Souleymane KONE, Karidioula Souleymane, Tehfour KONE, Simon SORO, Porlo Rigobert SORO, Félicien SEKONGO, Marc Kidou OUATTARA, Mamadou DJIBO, Aboubacar TOURE, Babou TRAORE, Ladji OUATTARA, Gnamiand N'DRIN, Dahafolo KONE, Adama ZEBRET and to release them on bail;

  3. iii. report to the Court on the implementation of the provisional measures ordered in this judgement within thirty (30) days, as from the date of notification of this Order.

Signed:

Ben KIOKO, Vice-Preside;

and Robert ENO, Registrar.

Done in Arusha, this Twenty second day in the month of April in the year Two Thousand and Twenty, in English and French, the French text being authoritiative.

Footnotes

1 Amini Juma v. United Republic of Tanzania (provisional measures) (2016) 1 RJCA 687, § 8; African Commission on Human and Peoples’ Rights v. Libya (provisional measures) (2013) 1 RJCA 149, § 10

2 The Respondent State withdrew from the ICCPR on 26 March 1993

3 Application No.001/2015 : Armand Guéhi v. United Republic of Tanzania, Ruling of 18 March 2016, § 20.

4 Application No. 062/2019: Sébastin Germain Marie Aikoue Ajavon vs. Republic of Benin, Ruling of 17 Avril 2020, § 61

5 IACHR, APPLICATION No. 10 208; Salvador Jorge Blanco v. Dominican Republic. IACHR annals. 1988–1989, doc. OAS/Ser. L/V 11.68. DOC.8 REV. 1, P. 55–59

References

ENDNOTES

1 Article 7 (right to a fair trial, legality principle, individualisation of punishment); Article 12 (freedom of movement and residence, right to seek and to obtain asylum, expulsion of non-nationals); and Article 18 (protection of the family, elimination of discrimination against women, protection of the woman and the child and protection of the aged and disabled persons).

2 Article 14 (independence of the judiciary, right to fair trial); Article 23 (protection of the family).

3 Guillaume Kigbafori Soro and Others v. Republic of Côte-d'Ivoire, No. 012/2020, Order for Provisional Measures, African Court on Human and Peoples’ Rights [Afr. Ct. H.P.R.] (Apr. 22, 2020), ¶ 13.

4 Id. ¶ 22.

5 Id. ¶ 33.

6 Id. ¶ 39.

7 Id. ¶ 40.

8 Sègnonna Horace Adjolohoun, “A crisis of design and judicial practice? Curbing state disengagement from the African Court of Human and Peoples’ Rights,” 20 African Hum. Rts. J. 22 (2020).

9 Id., p. 17.

10 Declarations and withdrawals are available on the Court's webpage: https://www.african-court.org/en/index.php/basic-documents/declaration-featured-articles-2.

11 See, in particular, the withdrawal's declaration of Benin.

12 The Consolidated Matter of the Tanganyika Law Society and Legal and Human Rights Centre v. United Republic of Tanzania/ Reverend Christopher R. Mtikila v. United Republic of Tanzania, Nos. 009/2011 and 011/2011, Judgment, African Court on Human and Peoples’ Rights [Afr. Ct. H.P.R.] (June 14, 2013); Actions pour la Protection des Droits de l'Homme v. Republic of Côte d'Ivoire, African Court on Human and Peoples’ Rights [Afr. Ct. H.P.R.], (Nov. 18, 2016).

13 Adjolohoun, supra note 8, pp. 39–40.