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Campagna Internazionale

US blamed over death row Mexicans

The International Court of Justice at The Hague has ruled that the US violated the rights of 51 Mexicans on death row in American prisons.

The court found that the prisoners did not receive a fair trial because they were not told of their rights to consular assistance.

Mexican lawyers argued that consular help could have made the difference between life and death.

Presiding judge Shi Jiuyong said the men's convictions should be reviewed.

"The US should provide by means of its own choosing meaningful review of the conviction and sentence" in all but one of the 52 cases presented, he said.

Arturo Dajer, legal adviser to Mexico's Department of Foreign Relations, called the ruling "a triumph of international law".

The 1963 Vienna Convention, which both countries have signed, required the men to be informed of their rights to consular aid.

Sovereignty

US lawyers have dismissed the case as a publicity stunt, claiming the men have already had fair trials.

The court ruled last year that three of the Mexican nationals on death row should be granted a stay of execution until it issued a judgement.

Washington argued that ruling infringed America's sovereignty over its criminal justice system.

The court's decisions are legally binding.

But in a similar case, the court ordered the US to stay the execution of a German national in 1999 - he was put to death nevertheless.

The current case has put pressure on Mexico to reform its own justice system.

Hours before the judgement, Mexico's President Vicente Fox announced a reform package that includes plans to substitute the death penalty, which exists for military personnel, with 30- to 60-year prison sentences.

The death penalty has not been applied in Mexico's army since 1961 and is theoretically reserved for the worst offences, such as treason or serious dereliction, the Associated Press reported.

MEXICO: World Court Rules U.S. Should Review 51 Death Sentences

The International Court of Justice on Wednesday ordered American courts to review death sentences imposed on 51 Mexicans in the United States, saying their rights under international law had been violated.

The decision, by the United Nations' highest court, was seen as a moral victory in Mexico and as a stinging rebuke to the United States.

In a firm ruling read out before the judges in the stately hall of the Peace Palace in The Hague, the court said the prisoners' rights to speak with Mexican consular officials after their arrests had been repeatedly violated.

It ordered the United States to undertake "an effective review" of the convictions and the sentences. The next Mexican to be executed in the United States is scheduled to die May 18 in Oklahoma.

President Vicente Fox of Mexico called the decision "a victory for international rights, for human rights."

Arturo Dager, a senior legal adviser to the Mexican Foreign Ministry, said Mexico "totally trusts that the United States will do the right thing and the necessary thing to fulfill this decision."

It is unclear whether American courts will heed the ruling, and federal officials reacted cautiously, saying they needed time to study the list of decisions. "It's a very complex ruling," said Adam Ereli, a State Department spokesman. "We'll decide, based on studying it, how we can go about implementing it."

The United States acknowledges the jurisdiction of the court to resolve disputes between nations arising under the 1963 Vienna Convention on Consular Relations, which allows people arrested abroad to meet with representatives of their governments and says detainees must be advised of this right. The United States regularly invokes the convention to visit Americans in foreign jails.

Although the laws of an international treaty should prevail over national law, the Bush administration has often criticized the application of international law. Even if it bows to the ruling, federal officials may not be able to compel states to heed the court.

Gov. Rick Perry, who succeeded President Bush in Texas, has said that "the International Court of Justice does not have jurisdiction in Texas."

If the decision is ignored, Mexican officials noted on Wednesday, they can return to the court, bringing further pressure. While the court's rulings are binding, it has no power to enforce them.

Mexico was the third country in five years to sue the United States for similar violations of the Vienna Convention, after Germany and Paraguay. It filed its complaint in January 2003 to halt the imminent execution of three of its citizens.

The United States did not deny that it had breached the convention. In the past, it apologized and promised better compliance. It also argued that the American practice of allowing defendants to ask for clemency provided an adequate remedy because it often resulted in pardons or in the commutation of death sentences.

But the court said an apology or a clemency hearing was not enough. Instead, it said, each case should be examined to see if a defendant suffered legal prejudice from not having early access to a diplomat.

"This is great news; it means my client's case will now be looked at again," said David Sergi, a lawyer from San Marcos, Tex., who was present in The Hague and represents Roberto Moreno Ramos, a Mexican awaiting execution in Texas.

Mr. Ramos was sentenced to death in 1992 for killing his wife. Mr. Sergi said he had evidence that Mr. Ramos was mentally retarded, which was not raised by his previous lawyers. "If the U.S. ignores this right to call your consul, why should the rest of the world honor it?" Mr. Sergi said.

Mexico's filing with the court specifically covered Mr. Ramos, another Texas prisoner, Csar Fierro, and Osbaldo Torres, who is scheduled to be executed in Oklahoma on May 18. There are Mexicans on death row in seven other states: Arizona, Arkansas, California, Florida, Nevada, Ohio and Oregon.

Human rights lawyers said the court's ruling had respected American sovereignty. It ruled that it was up to the United States to decide how it would review the cases and stressed that it was not debating whether any conviction or sentence was correct. "It is for the courts of the United States to examine the facts," the ruling said.

The court also rejected the demand by Mexico that all 51 convictions and death sentences be annulled. The decision, Mexican diplomats said, may affect the cases of almost 100 other Mexicans facing death sentences before American courts.

But the ruling aims to have even broader applications. The court said that because it was deciding on a principle, namely the obligation to abide by the Vienna Convention, its ruling applied to "other foreign nationals finding themselves in similar situations in the United States."

Reed Brody of Human Rights Watch, based in New York, said the ruling applied to more than 120 foreigners from 29 countries on death rows in the United States.

"The right to see your consul is not just a technicality, it is a way to avoid all kinds of errors or miscarriage of justice," Mr. Brody said. "Of course this right is just as important to Americans abroad." The convention covers 165 nations.

Mexico does not have a death penalty, except in its military code. Executions of Mexicans in American prisons are widely publicized and almost universally resented in Mexico. Mr. Fox canceled a scheduled visit in August 2002 to Mr. Bush's ranch in Texas to protest the state's execution of a Mexican.

The ruling was applauded across the political spectrum in Mexico, where even opposition politicians praised Mr. Fox for taking a stand against the United States in the international court.

Silvia Hernndez, a member of the opposition and president of the Mexican Senate's foreign relations committee, warned of an outcry should the states begin again to execute Mexican prisoners.

"That would be a deception," she said. "It would generate enormous distrust towards the American authorities, and it would send a very dangerous message that the United States only obeys favorable rulings under international law."

Gabriel Guerra Castellanos, a foreign policy analyst in Mexico City, said: "The United States usually does not pay much attention to the international court unless the court rules in its favor. It would be wrong for the United States to disregard this ruling. At a time when it is looking for allies everywhere around the world, it would be a huge mistake."

Human Rights Watch

MEXICO: U.S. Violated Rights of Mexicans on Death Row----International Court of Justice Orders Judicial Review of U.S. Convictions

The International Court of Justice today affirmed the importance of protecting the rights of foreign citizens prosecuted in the United States, Human Rights Watch said. The court ruled against the United States in a case brought by Mexico concerning the U.S. failure to inform 54 Mexicans arrested on capital charges of their right to talk to their consular officials.

The right to consular notification and assistance is required by the Vienna Convention on Consular Relations. This right enables governments' officials to provide assistance, including legal counsel, to help ensure fair proceedings for their citizens who may be at a disadvantage in criminal proceedings in foreign countries.

The United States, one of 168 countries party to the treaty, acknowledged that all 54 of the Mexican citizens had been tried, convicted and sentenced to death without being informed of their Vienna Convention rights. Mexico argued that consular help could have protected the defendants' due process rights.

"Today's decision could make the difference between life and death for foreigners prosecuted in the United States," said Jamie Fellner, director of the U.S. Program at Human Rights Watch. "Giving defendants access to consular officials means that they can get good defense lawyers-the surest way to avoid the death penalty."

In today's ruling in the Case concerning Avena and Other Mexican Nationals (Mexico v. United States of America) the International Court of Justice (ICJ) said that it was "for the courts" of the United States to provide "effective" review of the convictions to determine whether the violations caused "actual prejudice" to each defendant. It rejected the U.S. argument that failure to respect the right to consular notification could be rectified by simply raising that fact in a petition for clemency.

Mexico had asserted that the "standardless, secretive and unreviewable clemency process" was an insufficient remedy, and that redress of Vienna Convention violations required "not the hope of executive grace, but the right to legal review." The court agreed that clemency proceedings were no guarantee that the violations would be redressed.

In an interim ruling in February 2003, the ICJ ordered the United States to ensure that the three of the 54 Mexicans whose executions were imminent were not executed before the court issued its final decision on the merits. None has been executed, but Oklahoma has set May 18, 2004 as the date for the execution of one of them, Osvaldo Torres.

"The United States invokes the Vienna Convention to ensure protection for American citizens arrested, detained or imprisoned abroad," said Fellner. "Nevertheless, it has been reluctant to provide a meaningful remedy to foreign citizens whose right to consular notification has been violated in the United States."

The Avena case is the 3rd time in 5 years that countries have instituted proceedings in the International Court of Justice against the United States because of the failure of U.S. officials to notify foreign citizens arrested in the United States of their rights under the Vienna Convention.

In 2 earlier cases, brought by Paraguay and Germany on the eve of scheduled executions, the ICJ issued interim rulings ordering the United States not to execute the death row prisoners pending a final ICJ decision. The prisoners were nonetheless executed. Paraguay then dropped its case, but Germany pressed for a final ruling. In its final judgment in Germany's case in June 2001, the court ordered the United States "by means of its own choosing [to] allow the review and reconsideration of the conviction and sentence by taking account of the violation" of consular notification rights set forth in the Vienna Convention.

Today's ruling clarifies the meaning of "review and reconsideration" in its decision in the German case.

As Mexico argued before the ICJ, consular notification is particularly important in capital cases, where the lives of defendants are at risk. Mexico has a "Capital Legal Assistance Program" in the United States, which has intervened to protect the rights of Mexican nationals in approximately 110 capital cases. At least 20 foreign nationals have been executed in the United States in the last decade, nearly all without consular notification. Currently, more than 120 foreign nationals from 29 countries are on death row in the United States.

"Today's ruling puts teeth in the Vienna Convention by requiring effective legal review of convictions when defendants were not notified that they could contact their consulate," said Fellner. "Consular access protects the rights not only of foreigners in the United States, but also the rights of Americans abroad."

As the ICJ recognized, the United States has stepped up its efforts to inform state law enforcement authorities of the right to consular notification.

Human Rights Watch suggests that U.S. police reading defendants their "Miranda rights" should be required to tell them that if they are foreign nationals they have a right to communicate with their government. The U.S. courts should treat the failure to inform them of their right to consular notification the same as any other violation of Miranda rights.

Human Rights Watch opposes capital punishment in all circumstances. The death penalty is a form of punishment unique in its cruelty and is inevitably carried out in an arbitrary manner, inflicted primarily on the most vulnerable-the poor, the mentally ill, and persons of color. The intrinsic fallibility of all criminal justice systems assures that even when full due process of law is respected, innocent persons may be executed.

MEXICO: Court Says U.S. Violated Mexicans' Rights

The International Court of Justice on Wednesday ruled that the United States violated the rights of 51 Mexicans on death row and ordered their cases be reviewed.

The United Nations' highest judiciary, also known as the world court, was considering a suit filed by Mexico claiming 52 convicted murderers weren't given their right to assistance from their government.

"The U.S. should provide by means of its own choosing meaningful review of the conviction and sentence'' of the Mexicans, presiding judge Shi Jiuyong said.

Shi said the review, in all but three cases, could be carried out under the normal appeals process in the United States.

But for three men whose have already exhausted all other appeals, the court said the United States should make an exception and review their cases one last time.

The court found that in the remaining case, the convict had received his rights and his case didn't need to be reviewed.

At the heart of the Mexico-U.S. case is the 1963 Vienna Convention, which guarantees people accused of a serious crime while in a foreign country the right to contact their own government for help and that they be informed of that right by arresting authorities.

The world court is charged with resolving disputes between nations and has jurisdiction over the treaty. It found that U.S. authorities hadn't properly informed the 51 men of their rights when they realized they were foreigners.

Both the United States and Mexico were preparing reactions to the ruling.

The United States had argued the case was a sovereignty issue, and the 15-judge tribunal should be wary of allowing itself to be used as a criminal appeals court, which is not its mandate.

In hearings in December, lawyers for Mexico argued that any U.S. citizen accused of a serious crime abroad would want the same right, and the only fair solution for the men allegedly denied diplomatic help was to start their legal processes all over again.

Juan Manuel Gomez said that Mexico "doesn't contest the United States' right as a sovereign country to impose the death penalty for the most grave crimes," but wants to make sure its citizens aren't abused by a foreign legal system they don't always understand.

U.S. lawyer William Taft argued that the prisoners had received fair trials. He said even if the prisoners didn't get consular help, the way to remedy the wrong "must be left to the United States."

In its written arguments, the United States said that Mexico's request would be a "radical intrusion" into the U.S. justice system, contradicting laws and customs in every city and state in the nation.

"The court has never ordered any form of restitution nearly as far reaching as that sought by Mexico," the arguments said.

In 2001, a similar case came before the court filed by Germany to stop the execution of 2 German brothers who also had not been informed of their right to consular assistance. One brother was executed before the court could act. The judges ordered a stay of execution for the second brother, Walter LaGrand, until it could deliberate, but he was executed anyway by the state authorities of Arizona.

Under the court's statute, its judgments are "binding, final and without appeal." Its rulings have rarely been ignored, and if one side claims the other has failed to carry out the court's decision, it may take the issue to the U.N. Security Council.

When the court finally handed down the belated ruling in 2001, it chastised the U.S. government for not halting the LaGrand execution, and rejected arguments that Washington was powerless to intervene in criminal cases under the authority of the individual states.

Mexican President Vicente Fox canceled a visit to President Bush's ranch in 2002 to protest the execution of a Mexican citizen not mentioned in the world court suit. The visit finally took place earlier this month.

ICJ

Avena and Other Mexican Nationals

The Court finds that the United States of America has breached its obligations to Mr. Avena and 50 other Mexican nationals and to Mexico under the Vienna Convention on Consular Relations

Today the International Court of Justice, the principal judicial organ of the United Nations, delivered its Judgment in the case concerning Avena and Other Mexican Nationals (Mexico v. United States of America).

In its Judgment, which is final, without appeal and binding on the Parties, the Court, with regard to the merits of the dispute,

- finds by fourteen votes to one that, by not informing, without delay upon their detention, the 51 Mexican nationals referred to in paragraph 106 (1) above of their rights under Article 36, paragraph 1 (b), of the Vienna Convention on Consular Relations of 24 April 1963, the United States of America breached the obligations incumbent upon it under that subparagraph;

- finds by fourteen votes to one that, by not notifying the appropriate Mexican consular post without delay of the detention of the 49 Mexican nationals referred to in paragraph 106 (2) above and thereby depriving the United Mexican States of the right, in a timely fashion, to render the assistance provided for by the Vienna Convention to the individuals concerned, the United States of America breached the obligations incumbent upon it under Article 36, paragraph 1 (b);

- finds by fourteen votes to one that, in relation to the 49 Mexican nationals referred to in paragraph 106 (3) above, the United States of America deprived the United Mexican States of the right, in a timely fashion, to communicate with and have access to those nationals and to visit them in detention, and thereby breached the obligations incumbent upon it under Article 36, paragraph 1 (a) and (c), of the Convention;

- finds by fourteen votes to one that, in relation to the 34 Mexican nationals referred to in paragraph 106 (4) above, the United States of America deprived the United Mexican States of the right, in a timely fashion, to arrange for legal representation of those nationals, and thereby breached the obligations incumbent upon it under Article 36, paragraph 1 (c), of the Convention;

- finds by fourteen votes to one that, by not permitting the review and reconsideration, in the light of the rights set forth in the Convention, of the conviction and sentences of Mr. Csar Roberto Fierro Reyna, Mr. Roberto Moreno Ramos and Mr. Osvaldo Torres Aguilera, after the violations referred to in subparagraph (4) above had been established in respect of those individuals, the United States of America breached the obligations incumbent upon it under Article 36, paragraph 2, of the Convention;

- finds by fourteen votes to one that the appropriate reparation in this case consists in the obligation of the United States of America to provide, by means of its own choosing, review and reconsideration of the convictions and sentences of the Mexican nationals referred to in subparagraphs (4), (5), (6) and (7) above, by taking account both of the violation of the rights set forth in Article 36 of the Convention and of paragraphs 138 to 141 of this Judgment;

- unanimously takes note of the commitment undertaken by the United States of America to ensure implementation of the specific measures adopted in performance of its obligations under Article 36, paragraph 1 (b), of the Vienna Convention; and finds that this commitment must be regarded as meeting the request by the United Mexican States for guarantees and assurances of non-repetition;

- unanimously finds that, should Mexican nationals nonetheless be sentenced to severe penalties, without their rights under Article 36, paragraph 1 (b), of the Convention having been respected, the United States of America shall provide, by means of its own choosing, review and reconsideration of the conviction and sentence, so as to allow full weight to be given to the violation of the rights set forth in the Convention, taking account of paragraphs 138 to 141 of this Judgment.

Reasoning of the Court

In its Judgment the Court begins by outlining the history of the case. It recalls that on 9 January 2003 Mexico instituted proceedings against the United States of America in a dispute concerning alleged breaches of Articles 5 and 36 of the Vienna Convention on Consular Relations of 24 April 1963 in relation to the treatment of a number of Mexican nationals who had been tried, convicted and sentenced to death in criminal proceedings in the United States. The original claim related to 54 such persons, but as a result of subsequent adjustments by Mexico, only 52 individual cases are involved.

On 9 January 2003 Mexico also asked the Court to indicate provisional measures, and in particular to order the United States to take all measures necessary to ensure that no Mexican national was executed pending a final decision of the Court.

On 5 February 2003 the Court unanimously adopted an Order indicating such measures, stating inter alia that the United States of America shall take all measures necessary to ensure that Mr. Csar Roberto Fierro Reyna, Mr. Roberto Moreno Ramos and Mr. Osvaldo Torres Aguilera . . . are not executed pending final judgment in these proceedings.

The Court then examines four objections of the United States to the Courts jurisdiction and five to the admissibility of the claims of Mexico.

It rejects those objections after first having rejected the objection of Mexico to the admissibility of the United States objections.

Ruling on the merits of the case, the Court first addresses the question of whether the 52 individuals concerned had Mexican nationality only, or whether some of them were also United States nationals, as claimed by that State. Concluding that the United States has not proved that claim, the Court finds that the United States did have obligations (to provide consular information) under Article 36, paragraph 1 (b), of the Vienna Convention towards the 52 Mexican nationals.

The Court then examines the meaning of the expression without delay used in paragraph 1 (b) of Article 36. It finds that the duty to provide consular information exists once it is realized that the person is a foreign national, or once there are grounds to think so, but considers that, in the light inter alia of the Conventions travaux prparatoires the term without delay is not necessarily to be interpreted as meaning immediately upon arrest. The Court then concludes that, on the basis of this interpretation, the United States has nonetheless violated its obligation to provide consular notification in all of the cases save one.

The Court then takes note of the interrelated nature of the three subparagraphs (a), (b) and (c) of paragraph 1 of Article 36 of the Vienna Convention and finds, in 49 of the cases, that the United States has also violated its obligation under subparagraph (a) to enable Mexican consular officers to communicate with, have access to and visit their nationals; while, in 34 cases, it finds that the United States has also, in addition, violated its obligation under subparagraph (c) to enable Mexican consular officers to arrange for legal representation of their nationals.

The Court then turns to Mexicos submission in relation to paragraph 2 of Article 36, whereby it claims that the United States violated its obligations under that paragraph by failing to provide meaningful and effective review and reconsideration of convictions and sentences impaired by a violation of Article 36 (1), inter alia as a result of the operation of the procedural default rule. The Court begins by observing that the procedural default rule has not been revised since it drew attention in its Judgment in the LaGrand case to the problems which its application could cause for defendants who sought to rely on violations of the Vienna Convention in appeal proceedings.

The Court finds that in three cases paragraph 2 of Article 36 has been violated by the United States, but that the possibility of judicial re-examination is still open in 49 of the cases.

Turning to the legal consequences of the abovefound breaches and to what legal remedies should be considered, the Court notes that Mexico seeks reparation in the form of restitutio in integrum, that is to say partial or total annulment of conviction and sentence, as the necessary and sole remedy. The Court, citing the decision of its predecessor, the Permanent Court of International Justice, in the Chorzw Factory case, points out that what is required to make good the breach of an obligation under international law is reparation in an adequate form. Following its Judgment in the LaGrand case the Court finds that in the present case adequate reparation for violations of Article 36 should be provided by review and reconsideration of the convictions and sentences of the Mexican nationals by United States courts.

The Court considers that the choice of means for review and reconsideration should be left to the United States, but that it is to be carried out by taking account of the violation of rights under the Vienna Convention.

The Court then addresses the function of executive clemency.

Having found that it is the judicial process that is suited for the task of review and reconsideration, the Court finds that the clemency process, as currently practised within the United States criminal justice system, is not sufficient in itself to serve that purpose, although appropriate clemency procedures can supplement judicial review and reconsideration.

Finally, with regard to Mexicos request for the cessation of wrongful acts by the United States, the Court finds no evidence of a regular and continuing pattern of breaches by the United States of Article 36 of the Vienna Convention. And as to its request for guarantees and assurances of nonrepetition the Court recognizes the United States efforts to encourage implementation of its obligations under the Vienna Convention and considers that that commitment by the United States meets Mexicos request.

At the end of its reasoning, the Court emphasizes that, in the present case, it has been addressing issues of principle from the viewpoint of the general application of the Vienna Convention. It observes that, while the present case concerns only Mexicans, its Judgment cannot be taken to imply that the Courts conclusions do not apply to other foreign nationals finding themselves in similar situations in the United States.

The Court finally points out that its Order of 5 February 2003 indicating provisional measures mentioned above, according to its terms and to Article 41 of the Statute, was effective pending final judgment, and that the obligations of the United States in that respect are, with effect from the date of the Judgment, replaced by those declared in this Judgment. The Court observes that it has found in relation to the three persons concerned in the Order (among others), that the United States has committed breaches of its obligations under Article 36, paragraph 1, of the Vienna Convention; and that moreover, in respect of those three persons alone, the United States has also committed breaches of Article 36, paragraph 2. The review and reconsideration of conviction and sentence required by Article 36, paragraph 2, which is the appropriate remedy for breaches of Article 36, paragraph 1, has not been carried out.

The Court considers that in these three cases it is for the United States to find an appropriate remedy having the nature of review and reconsideration according to the criteria indicated in the Judgment.

Composition of the Court

The Court was composed as follows: President Shi; Vice-President Ranjeva; Judges Guillaume, Koroma, Vereshchetin, Higgins, Parra-Aranguren, Kooijmans, Rezek, Al-Khasawneh, Buergenthal, Elaraby, Owada, Tomka; Judge ad hoc Seplveda; Registrar Couvreur.

President Shi and Vice-President Ranjeva append declarations to the Judgment of the Court; Judges Vereshchetin, Parra-Aranguren and Tomka and Judge ad hoc Seplveda append separate opinions to the Judgment of the Court.

A summary of the Judgment is published in the document entitled Summary No. 2004/1, to which summaries of the declarations and opinions attached to the Judgment are annexed. The present Press Release, the summary and the full text of the Judgment also appear on the Courts website under the Docket and Decisions headings (www.icj-cij.org).

05/04/04

Foreigners on death row

The International Court of Justice has ruled that 51 Mexican nationals on death row in the United States are owed a review of their cases because they were not provided access to representatives of their government when first arrested, in violation of international law. The Bush administration needs to heed the court's order, not only as a moral and legal imperative, but as a matter of protecting American citizens overseas.

Imagine an American being executed in Mexico after being denied a visit by an American consular official, and you get a sense of why this case arouses such anger in Mexico .

The 1963 Vienna Convention on Consular Relations establishes the right of diplomats to be granted immediate access to their citizens arrested in a foreign country. It is vital for the United States - more so than for any other nation - that this be strictly observed. American tourists and businessmen are often targeted by less-than-scrupulous law enforcement officers in foreign countries, and the intervention of consular officials is often the only way to ensure due process.

For the Bush administration to compel states to review these cases - a treaty ratified by Congress trumps state laws under the Constitution - would also provide a muchneeded affirmation that Washington still believes in international law.

Citizens in many democracies around the world are appalled that the United States still has a death penalty, an emotion that originally tainted their view of George W Bush, who presided over many executions as Texas governor. But the ruling out of The Hague is not meant to challenge the death penalty. In fact, the court does not ask for any sentences to be annulled; it asks only for a complete review to remedy the human rights violation.

In the future, American law enforcement agencies must do a better job of notifying the appropriate consular officials when a foreign national is arrested. For now, Washington should stop the executions of the 51 Mexicans. The alternative, to ignore the international court's decision, would poison relations with Mexico , send a signal that the United States doesn't take its international obligations seriously and - worst of all - imperil Americans overseas.