The Ghost of Causation in International Speech Crime Cases *

In its best-known ruling on incitement to genocide, the ICTR described that crime as an unequivocal cause of mass killing. The tribunal said of the defendant Hassan Ngeze, a newspaper editor, “He poisoned the minds of his readers, and by words and deeds caused the deaths of thousands of innocent people.” ¹ Sentencing the radio executive Ferdinand Nahimana to life imprisonment ² in the same case, the judges told him, “Without a firearm, machete, or any physical weapon, you caused the deaths of thousands of innocent civilians.” ³