Even if Kenya’s recent reforms were motivated by the ICC’s indictments, the 2013 elections were still marked by violence which “as of February 2013, had claimed more than 477 lives and displaced another 118,000 people.” [1]  Despite many African governments’ initial enthusiasm for the ICC, the African Union has since openly challenged the Court’s investigations and Kenyan authorities have been doing their utmost to obstruct the ICC’s investigations. [2]  [1] Human Rights Watch  [2] Evenson