to 2000. This ruling, however, does not protect those charged who are residing outside of El Salvador. The Conviction of Inocente Orlando Montano: The Erosion of Impunity Fourteen years after the massacre at UCA, there is a break in the case. On September 11, 2012, Inocente Orlando Montano was convicted in a US federal court on charges of immigration fraud and perjury. Montano had lied on applications for temporary protective status (TPS), concealing his former occupation as a military commander in the Salvadoran army. Assistant US Attorney John Capin said Montano was "motivated by a desire to conceal human rights violations that he participated in, or sought to conceal what he was involved in in El Salvador." 24 Withholding this information was no small omission. Montano was among the high-ranking military officers indicted by a Spanish court in 2011 for collusion in the UCA massacre of November 16, 1989. Now, that court is seeking Montano's extradition from the US to stand trial in Spain. He is currently under house arrest pending his sentencing hearing scheduled for December 18, 2012. While it is not clear whether the US will comply with this request, a U.S. Immigration and Customs Enforcement (ICE) press release does not show much sympathy for Montano: Today's guilty plea reinforces our message to those who violate human rights worldwide: the United States will not turn a blind eye to your foreign crimes if you seek to hide here," said ICE Director John Morton. "ICE's Homeland Security Investigations will