Fourth Circuit Denies Immunity to Ex-Salvadoran Colonel in Journalist Killings
The Fourth Circuit ruled former Colonel Reyes Mena cannot claim sovereign immunity in the killings case.
Why it matters: This ruling signals that violations of international human rights norms, like extrajudicial killings, are not protected by sovereign immunity, reinforcing legal accountability. International law practitioners should note its impact on human rights litigation standards.
- On July 8, 2026, the Fourth Circuit rejected former Salvadoran Colonel Mario Adalberto Reyes Mena’s immunity plea under the Foreign Sovereign Immunities Act (FSIA).
- Reyes Mena was convicted in June 2025 by a Salvadoran court and sentenced to 15 years for the 1982 killings of four Dutch journalists.
- A 1992 U.N. Truth Commission report found Reyes Mena orchestrated the ambush that killed journalists Jan Kuiper, Koos Koster, Hans ter Laag, and Joop Willemson.
- The lawsuit was filed in the U.S. District Court for the Eastern District of Virginia, where Reyes Mena currently resides, amid ongoing extradition efforts.
On July 8, 2026, the U.S. Court of Appeals for the Fourth Circuit issued a landmark ruling denying sovereign immunity to former Salvadoran Colonel Mario Adalberto Reyes Mena in a case related to the killing of four Dutch journalists in 1982. The court held that violations of international norms, including extrajudicial killings, are not shielded by the Foreign Sovereign Immunities Act (FSIA).
The Dutch journalists—Jan Kuiper, Koos Koster, Hans ter Laag, and Joop Willemson—were ambushed and killed by Salvadoran soldiers while covering El Salvador's civil war. A 1992 United Nations Truth Commission attributed responsibility for orchestrating the ambush to Reyes Mena.
In June 2025, a Salvadoran court convicted Reyes Mena and two other former military officers, sentencing them to 15 years in prison for the murders. The victims’ families have since pursued further accountability through U.S. courts where Reyes Mena currently resides. The lawsuit was filed in the Eastern District of Virginia, focusing on violations that the appeals court confirmed fall outside sovereign immunity protections.
Lawyers for the victims' families highlighted the brutality of the Salvadoran Security Forces' actions, describing the killings as an attempt to suppress independent media coverage of the conflict. The ruling by the Fourth Circuit emphasizes that such acts cannot be shielded by sovereign immunity, reinforcing the principle that serious human rights abuses are subject to legal scrutiny.
Efforts to extradite Reyes Mena to El Salvador continue, underscoring ongoing international cooperation in addressing past human rights violations. This decision also sets an important precedent for future cases involving alleged breaches of international law and the limitations of sovereign immunity defenses.
By the numbers:
- July 8, 2026 — Date of the Fourth Circuit ruling
- 1982 — Year of the Dutch journalists' killings
- June 2025 — Date of Salvadoran court conviction
- 15 years — Prison sentence for Reyes Mena and co-defendants
- 1992 — Year of the U.N. Truth Commission report
What's next: Extradition proceedings against Reyes Mena remain ongoing, with U.S. courts likely to play a key role in future accountability efforts.