The Making of Muhammadu Buhari As A Bad Boy, Courtesy of The West: His Puppeteers
October 29, 2020 by Oluwole Oluborode
By Chiamaka Echebiri*
Zombie no go go, unless you tell am to go (Zombie)
Zombie no go stop, unless you tell am to stop (Zombie)
Zombie no go turn, unless you tell am to turn (Zombie)
Zombie no go think, unless you tell am to think (Zombie)
– Fela Kuti singing “Zombie” in West African Pidgin English
In 1977, Fela Kuti, a Nigerian artist who was also the best known architect of Afrobeats, a pan-Africanist, and political activist, released an album titled “Zombie” as a scathing critique of the Nigerian army. In the title track, Fela narrates the motion of Nigerian soldiers and likens them to zombies taking orders against Nigerians without minds of their own. Fela’s bold and rebellious remarks did not go without a response. Over a thousand soldiers stormed into Fela’s commune, the Kalakuta Republic, and burned down his and his band members’ homes, his recording studio, recording equipment, and his band’s master tapes. Fela was beaten near death and his elderly mom, Funmilayo Ransome-Kuti who was also a political activist, pan-Africanist as well as a staunch proponent of women’s rights, was thrown off a building and died soon after from the sustaining injuries.
For those who are surprised about the repressive violence against #EndSARS and #EndSWAT protesters protesting against police brutality and the lack of economic opportunities, don’t be. And for those, who believe America is much better with welcoming and allowing for public dissent, must I remind you of the war waged against Black Lives Matter protesters this past summer that left some with gaping holes in their heads from rubber bullets, some without an eye, and others with wounds from being pushed or beaten by the police? Not to mention, the United States has a history of training Nigerian police. Since 2006, the United States has trained the Nigerian Police Force, including its Special Anti-Robbery Squad branch, through AFRICOM (the United States Africa Command or USAFRICOM)measures to “combat terrorism” and bring “peace and prosperity” to Africa. For avid social media users, what comes to mind at this very moment, I imagine, is the meme of the two spidermen pointing at one another.
Admittedly, the spiderman meme is too simplistic of a representation of the sociopolitical connection of Nigeria to the United States. A deeper dive lies in the poignant and captivating words of Mbachu Stephanie, a 21-year-old Nigerian protester who went viral for rebuking President Buhari by declaring in a televised news interview: “Buhari has been a bad boy, he has been a bad boy!” As we scroll through our social media feeds and see the bloodied bodies, the bloodied flag, and the bloodied streets we must be vigilantly mindful of the role of the West, the masterful puppeteers, in the making of President Buhari, the bad boy.
The creation of the bad boy started with the West’s interest in Africa to invade, occupy, and expropriate. The continued interest for Africa to remain under Western control through the usage of the bad boy is to invade, occupy, and expropriate.
I. The West Entered Africa and Never Left
Between the years of November 15, 1884 and February 26, 1885 the scramble for Africa ensued at the Berlin Conference. Present were European powers such as the U.K., France, Spain, Portugal, and Germany, as well as the United States, to name a few. They assembled after the abolition of American chattel slavery, to promote “legitimate commerce” which replaced the old dynamic of Western and African relations of slavery with the colonization of Africa. As the leaders of the globalization of capitalism, they believed procuring new markets and raw materials was necessary. Another motivator for the European nations was their respective desires to pompously prove their dominance against rival European nations and acquiring a colony was a viable way of exhibiting their power. The quest for colonies started out as a contest. To prevent their rivalry from getting to the brink of war, in a white supremacist team effort, they decided to work together to arbitrarily partition Africa, without the consent of indigenous Africans, into different European controlled colonies that they proceeded to invade, expropriate, and exploit. Through consensus, European countries “divided the continent of Africa into spheres of resources and influence.” Look at a map of Africa, the horribly drawn scribbly lines partitioning one country from another was the result of their breathtaking creativity. These constructed boundaries were a detriment to African ethnic groups: “…boundaries drawn by Europeans often divided ethnocultural and…indigenous groups, sometimes bringing enemies under the same colonial occupation causing strife that still exists today.” Although, the United States did not claim a colony, they attended the conference, they were complacent, and they benefitted from the white supremacist team effort.
Dismantling the traditional African states that existed pre-European colonialism did not happen overnight and was not, by any means, easy. The Berlin Conference instructed European forces to implement a military conquest in their respective colonies because “effectively occupying” Africa was the only way to assert full control and dominance.Traditional African armies that fought back, resisting colonial invasion, gradually realized that their conventional military fighting tactics were no match against European technology such as the maxim gun. The maxim gun made almost all attempts of military conquest in Africa successful. After the imposition of colonial rule was solidified, African autonomy in all facets of African livelihood was effectively terminated.
Military conquest opened the door for colonialism and the stripping of unqualified African agency; this was the result in most cases of direct and settler rule. Indirect rule was a bit different—in most cases, it required the use of African rulers and chiefs as puppets for Europeans “governing” from afar. Traditional African rulers obtained a privileged status, but not absolute rule, in the colonial system and were instructed to accept European hegemony, ensure the colonial order, encourage people to labor for the colonial system, and collect taxes. Typically, rulers would be replaced if they did not adhere to these guidelines. At times, colonizers exacerbated ethnic group rivalries by endorsing certain ethnic groups to maintain dominance over other ethnic groups. Other than the Rwandan genocide, the Biafran War, which occurred seven years after Nigerian gained its “independence,” precisely exemplifies ethnic conflicts in many African countries over the division of power and resources.
These various tactics of the colonial system made African sovereignty obsolete, even post-independence, because African rulers were used as a pacification instrument to control and subdue people. European metropoles operating as puppet masters were vital to the success and longevity of the European colonial regime. The desire for each European force to secure colonies was the same, but the motives were quite different. Despite the intent of each country, their colonial actions had deleterious effects across the African continent.
The scramble for Africa and the subsequent colonization of African countries disenfranchised Africans from exercising true sovereignty in their respective countries. The methods of disenfranchisement were not only political and economic, they were also educational and religious. Namely, another stronghold that constrained Africans was the imposition of missionaries bringing Africans out of their “savagery” and “pagan” practices via introducing them to “civilization,” a Western interpretation of Christianity, and indoctrinating Africans with the idea of Europeans as superior.
II. The Shift from Indirect Rule to Yet More Insidious Indirect Rule
European colonization of Africa led to the underdevelopment of Africa which is diametrically related to the development of the West. In true White savior fashion, the pervasive underdevelopment of Africa discourse gave rise to the Bretton Woods Conference of 1944. Forty-four countries, including the United States, congregated to formulate a new economic policy that would determine “both the goals of development and the means for achieving them” for all of Africa. The Bretton Woods economic policy included Structural Adjustment Programs (SAPs)—International Monetary Fund (IMF) and World Bank issued loans—that masqueraded behind a humanitarian and philanthropic facade, but in actuality imposed high unpayable loans on African countries under “conditionalities.” These conditions were austerities: African nations were mandated to cut social and governmental spending, establish an economy centralized on exporting goods, uplift any restrictions on imported goods, eliminate state subsidies, increase power of foreign investors, limit tax for multinational corporations, and so forth. Predatory unpayable loans from former colonizers to their economically destabilized formerly colonized countries, is what the West called humanitarianism. Ultimately, SAPs exposed how the IMF and the World Bank—both controlled by the U.S. and Europe—dominate the political and economic state of “undeveloped” countries. These austerities flaunted how the West still held control over Africa even after colonialism. Also, austerity measures intentionally lessened the power of Africans to have an economic or political say in their respective countries. The resulting growth of poverty in African countries can be traced back to SAPs.
Unlike the Berlin Conference, the U.S. was more of an active participant in the Bretton Woods Conference. Sprouting from SAPs, the U.S. forwarded an economic policy that contained ridiculously high interest rates for underdeveloped countries. These systems are associated with what we now call neo-colonialism which keeps formerly colonized countries in perpetual debt. The emanating African debt made it possible for the Bretton Woods institution to control the economic landscape of African countries. Consequently, these countries are economically dependent on the West. Simply put, their independence is in name only.
Tethered to the underdevelopment discourse were non-governmental organizations (NGOs) which furthered Europe’s imperial rule of Africa. NGOs continued the colonial missionary agendas of inculcating Africans with the belief that they were backwards and inferior. Through NGOs, we get the white savior complex in which the fate of Africa rests on the altruistic aid of the West.
African countries have remained under perpetual Western rule since the scramble for Africa— even as European countries (as well as the United States) rule from afar. Today, as #EndSARS is capturing international attention, we must not divorce the Nigerian government’s tactics and abuse of its citizens from how African countries were created via the arbitrary drawing of boundaries that separated ethnic groups and forcibly connected ethnic groups. The history of the Berlin Conference and the Bretton Woods Conference makes the idea of the U.S. and the U.K. imposing sanctions on the Nigerian government to stop the massacres and overall war they are waging on their own people quite laughable. Why would they do such a thing in good faith when they are the puppeteers? Why would Britain help disband the Nigerian Police Force when they made it?
III. Local and Continued Resistance to the West
In pre-colonial Nigeria (what we now call Nigeria), many ethnic groups relied on traditional public safety methods that derived from community-oriented understandings and were intertwined with social and religious beliefs.Violence was not central to this equation, since social institutions such as enforcement measures from formal organizations, hunters, farmers, or gathers would maintain public safety. During the British colonial rule of Nigeria, they instituted local decentralized northern and southern police forces. The first police force was established in the Lagos colony in 1861. Mind you, Lagos, Nigeria is where some of the first #EndSARS protests took place. The division between the Hausa ethnic group and the Yoruba, Igbo, and other ethnic groups were first manufactured by Great Britain, the puppeteer. For instance, during the creation of Nigerian police, in the Lagos colony (located in what is now southern Nigeria), Britain strategically used officers from the “linguistically and culturally distinct” Hausa ethnic group located in northern Nigeria to police residents in Lagos colony. A consistent theme of the European colonial regime in Africa was to divide and conquer: “…many of the ethnic and regional cleavages which plague contemporary Africa had their roots in the administrative politics of the colonial era which favored certain traditional authorities, regions, and ethnic groups over others.” Britain used Hausa people as puppets to police the local community in Lagos colony, to divide and conquer by alienating the police from the people they were policing. Inciting ethnic strife helped Britain to rule from afar and maintain control of natural resources. Evidently, policing advanced the economic and political interests of colonizers because, as instructed, policemen violently suppressed Nigerian resistance to British colonization. The discord between the Nigerian police and the Nigerian people is not new and the brutal practices that were critical to its origins persist to this day. In the 1930s the various factions of the Nigerian police were conglomerated into a centralized and federally administered institution: The Nigerian Police Force. The basic functions of the police remain unchanged even post-independence in the 1960.
The mistrust of the police remained unchanged too because of how the police, as puppets, assisted in the colonial control of Nigerians pre-independence. Since the mid-twentieth century, military personnel and the police have been deployed to cement authoritarianism. Isaac Boro, is well known as one of the first people to stand up to foreign oil companies usurping Nigerian natural resources. He left college to lead a demonstration, in the 1960s, to rebelliously vocalize how the oil belonged to the people of the Niger-Delta and how it should be used to their exclusive benefit.The Nigerian government responded by deploying the Nigerian army to arrest him and his comrades. In 1970 more condemnation over the resource extraction of Nigerian oil was voiced by Ogoni Chiefs and Elders of the Ogoniland in the Niger-Delta. They formally complained to the local Military Governor that Shell’s oil operation was “seriously threatening the well-being, and even the very lives” of the Ogoni. Regular blow outs and other regularities of chemical emissions from Shell’s oil operation led to widespread pollution that saturated local rivers with crude oil, the source the Ogoni people depended on for water and other essential uses, destroyed vegetation, and contaminated the air with ghastly substances.
Between the 1970s and the 1980s, many protests arose from the Ogoni and the Iko people. In one of these protests, held in 1987, a paramilitary arm of the Nigerian Police Force, the Mobile Police Force also known as the “kill-and-go” were ordered by the Nigerian government and its puppeteer at the time, Shell, to quash the protest. In executing its zombie-like orders, the kill-and-go demolished forty homes leaving 350 people homeless. The idea that the Nigerian government was working in concert with Shell, was speculated at the time. Throughout the multi-generational condemnation of Shell, thousands of Ogoni activists were executed. In 1995, Shell colluded with the Nigerian government in the political detainment and execution-by-hanging of nine Ogoni activists (known as the Ogoni 9).Among the Ogoni 9, was Ken Saro-Wiwa, a writer and an ardent environmental activist against Shell and other foreign companies poisoning the environment to commercially profit from the Ogoniland oil. In the struggle, he founded and spearheaded the Movement for the Survival of the Ogoni People (MOSOP). In 2009 the speculations of collusion were proven to be true: court records arising from suits brought against Shell by the families of the assassinated Ogoni activists, revealed that Shell paid the Nigerian military to violently suppress demonstrators by torturing, raping, and killing them.
IV. Fighting The Bad Boy Today
Today, the centralized Nigerian Police Force is headed by the Inspector General of Police who is appointed by and reports to the President. The President holds the overall operational control as granted by the Nigerian Constitution. So, when thinking about SARS, Buhari has indeed been a bad boy because he, or at least members of his presidential administration, authorizes the actions of the police and the army. Western influence such as the Berlin Conference, the Bretton Woods Conference, and AFRICOM created bad boys. President Buhari can never honestly say that he is unaware of the military led massacre in Lekki where at least twelve protesters were slaughtered: he is the commander-in-chief of the Nigerian armed forces. Bad boy Buhari cannot honestly say he is unaware of who is responsible for the Oyigbo River State massacre (that is also believed to have been led by the military): he receives intelligence from the National Security Advisor in his presidential cabinet (modeled after the American executive branch). As I write, fifty-six to sixty-nine people have been killed during the #EndSARS protests and others have sustained life-altering injuries. Buhari is a bad boy and if history is an indicator of the future, Buhari’s successor will be a bad boy too, and the one after that, and so on. The capitalistic interests of countries like the U.S., masked as foreign policy, and the legacy of colonialism and its progenies (e.g., neo-colonialism) means that Nigeria will continue to produce bad boys as presidents and government leaders, courtesy of the West.
So, what can we do to help Nigerians? Many genuinely want to show solidarity with the Nigerian protesters in helping them gain the true sovereignty that many before them struggled to obtain. In wanting to help, let us absorb the words Seun Kuti—who follows in his father’s and grandmother’s, Fela and Funmilayo Ransome-Kuti’s, footsteps as an artist and activist—said while speaking West African Pigeon English in his Instagram live: “The Nigerian army was created to kill Black people to protect Western interest. Nothing has been done to change that.” Before signing petitions to have the U.S. or the U.K. sanction the Nigerian government, we must understand that whether they sanction Nigeria or not, the U.S. and U.K. will continue to act as puppeteers of the Nigerian army and police and expropriate Nigerian resources. U.S. sanctions rooted in so-called humanitarian efforts, will be counterproductive to Nigeria. Let’s be clear: sanctioning Nigeria will plummet their economy which is already destabilized from the legacy of colonialism and its progenies. The U.S. is a global power, and if it sanctions Nigeria there will be a domino effect in that other countries will follow, which will sink the Nigerian economy, and make them vulnerable to further exploitation. Likewise, we must abolish AFRICOM and all current Western influence of the Nigerian government, military, and police. If we are vigilantly mindful, we will notice rebranding attempts, because there will be rebranding attempts. As we have seen before our eyes SWAT is nothing more than a rebranding of SARS.
I urge all who want to show solidarity with #EndSARS protesters to support the Feminist Coalition, a grassroots organization fundraising for protesters; Diasporans Against SARS, a group of people in the Nigerian diaspora mobilizing to fundraise for medical treatment, food, water, and other aid for protesters; and Assata Collective, a mutual aid fund raising money for trans and queer Nigerians protesters who face both police brutality and, unfortunately, violence from other protesters as discriminated gender and sexual orientation minorities. If we have learned anything from the hit TV show “The Walking Dead” and zombie-themed movies, we know that to quell zombies we must aim for their head to reach the brain. In supporting organizing and mobilizing efforts to raise funds for #EndSARS protesters, instead of begging the U.S. or the U.K. to intermingle, we strategically aim for the head. And by understanding the history behind police brutality and the oppression of those who dared envisioned true freedom, we reach the brain, the bastion of the puppeteer, and come steps closer to the complete and total sovereignty of Nigeria—free from colonialism, free from bad boys, and free from their puppeteers.
[*] Staff Editor, Geo. J. L. & Mod. Crit. Race Persp.; J.D. Candidate, Georgetown University Law Center (L’2021), © 2019, Chiamaka Echebiri.
 West African Pidgin English is a creole that originated from the trans-Atlantic slave trade as a lingua franca amongst different ethnic groups who shared no common language. Pidgin or Pidgin English, its diminutives, is a mixture of English and local languages. See Pidgin – West African lingua franca, BBC News (Nov. 16, 2016), https://www.bbc.com/news/world-africa-38000387.
 See, e.g., Brad Smithfield, Over a thousand Nigerian soldiers assaulted Fela Kuti’s commune and recording studio, the Kalakuta Republic, brutally murdering his mother and burning the compound to the ground, Vintage News (Mar. 6, 2017), https://www.thevintagenews.com/2017/03/06/over-a-thousand-nigerian-soldiers-assaulted-fela-kutis-commune-and-recording-studio-the-kalakuta-republic-brutally-murdering-his-mother-and-burning-the-compound-to-the-ground/.
 #EndSARS is a mass resistance movement against a branch of the Nigerian Police Force, the “Special Anti-Robbery Squad,” that engages in extortion, harassment, torture, and killings of Nigerian people, especially Nigerian youth. SeeSada Malumfashi, Nigeria’s SARS: A brief history of the Special Anti-Robbery Squad, BBC News (Oct. 22, 2020), https://www.aljazeera.com/features/2020/10/22/sars-a-brief-history-of-a-rogue-unit. On October 11, 2020, President Buhari dissolved SARS. SWAT (Special Weapons and Tactics) is a replacement of SARS and Nigerians have identified it as SARS by another name. Nigerians quickly realized the rebranding and pushed #EndSWAT on social media. See End Swat: Nigerians reject police unit replacing hated Sars, BBC News (Oct. 14, 2020), https://www.bbc.co.uk/news/world-africa-54531449 [hereinafter End Swat]; End Sars protests: People ‘shot dead’ in Lagos, Nigeria, BBC News (Oct. 20, 2020), https://www.bbc.com/news/world-africa-54624611.
 See, e.g., Knvul Sheikh & David Montgomery, Rubber Bullets and Beanbag Rounds Can Cause Devastating Injuries, N.Y. Times (June 12, 2020), https://www.nytimes.com/2020/06/12/health/protests-rubber-bullets-beanbag.html.
 See Jackie Salo, Protester loses eye after being struck by police tear gas canister, N.Y. Post (June 1, 2020), https://nypost.com/2020/06/01/protester-loses-eye-after-being-struck-by-police-tear-gas-canister/, and Linda Tirado, I came to the Minneapolis protests to cover police aggression. Then I became the victim of it., NBC News (June 1, 2020), https://www.nbcnews.com/think/opinion/i-came-cover-aggression-minneapolis-then-i-became-victim-it-ncna1221241.
 See Adam Gabbatt, Protests about police brutality are met with wave of police brutality across US, Guardian (June 6, 2020), https://www.theguardian.com/us-news/2020/jun/06/police-violence-protests-us-george-floyd.
 U.S. Mission Nigeria, U.S. Human Rights Training to the Nigerian Police Force (Mar. 6, 2017) https://ng.usembassy.gov/u-s-human-rights-training-nigerian-police-force/.
 In 2006, the Bush administration created a U.S. military structure for Africa to secure access and control over African oil under the guise of combating the “global war on terror.” U.S. military intervention in Africa was always about resource control and the U.S. often concocted fabrications of terrorist incidents to further justify militarization of the continent. The attempts to recast Africa as a conflict and terror-ridden continent led to the creation of AFRICOM resulting in U.S. military architectures overseeing Africa’s oil- and gas-producing countries to this day. President Bush claimed the purpose of AFRICOM was to, “…enhance our efforts to help bring peace and security to the people of Africa and promote our common goals of development, health, education, democracy, and economic growth in Africa.” AFRICOM is a rebranding of EUCOM (European Command), which did a worst job at disguising its true purpose of resource extraction and political and economic influence. AFRICOM is also a replacement of Trans-Saharan Counter-Terrorism Initiative (TSCTI) and Pan Sahel Initiative (PSI). Since its inception, AFRICOM has not achieved its stated purpose, instead it has it has “undermined democratic expression” and “created instability.” See Jeremy Keenan, US militarization in Africa: What anthropologists should know about AFRICOM, 24 Anthropology Today 16, 16-20 (2008).
 Justin Cronje, Africom continues to combat terrorism in Africa amidst COVID-19, defenceWeb, https://www.defenceweb.co.za/featured/africom-continues-to-combat-terrorism-in-africa-amidst-covid-19/ (last visited Oct. 24, 2020).
 See Know Your Meme, Spider-Man Pointing at Spider-Man (last updated Feb. 2020), https://knowyourmeme.com/memes/spider-man-pointing-at-spider-man.
 By the “West,” I mean Europe and the United States.
 Patrick Gathara, Berlin 1884: Remembering the conference that divided Africa, Al Jazeera (Nov. 15, 2019), https://www.aljazeera.com/opinions/2019/11/15/berlin-1884-remembering-the-conference-that-divided-africa/.
 Colonization of Africa: Berlin Conference, Arcgis.Com, https://www.arcgis.com/apps/MapJournal/index.html?appid=6df9eef17b93493da8a1353777aa2a88#:~:text=The%20Berlin%20conference%20included%2013,Kingdom%2C%20and%20the%20United%20States(last visited Oct. 24, 2020).
 Sheldon Gellar, The Colonial Era, in Africa 3, 122 (Phyllis M. Martin & Martin O’Meara eds., Indiana University Press 1977).
 Id. at 123.
 Id. at 122.
 Dr. Jemima Pierre, Professor, Africa and The World: Abolition, “Legitimate Commerce,” and the Scramble for Africa, Lecture at the University of California, Los Angeles (Jan. 31, 2017).
 Gellar, supra note 19, at 125.
 Id. at 126.
 Pierre, supra note 23.
 Gellar, supra note 19, at 132.
 Id. at 125.
 Pierre, supra note 23.
 Portugal wanted gold to “boost their commercial and maritime enterprises.” Dr. Jemima Pierre, Professor, Africa and The World: African Enslavement – Transatlantic Slave Trade, Lecture at the University of California, Los Angeles (Jan. 26, 2017). Along the way, Portugal eventually managed to come to an agreement with African rulers which allowed them to acquire African labor for west African colonized islands. Id. Unlike Portugal, the Spaniards were interested in expropriating land, establishing mines to obtain metals, and securing a labor force. Id. The Dutch were responsible for bringing over 500,000 Africans to the Americas as enslaved commodities. Id. France failed at establishing a trading post, but excelled at planting sugars and using the Dutch’s collection of purchased African slaves. Id. Moreover, Britain’s main purpose was the colonization of African countries for economic gain. Id.
 The Bible and the Gun (Mitchell Beazley Television 1984).
 Gellar, supra note 19, at 126.
 See Firoze Manji & Carl O’Coill, The Missionary Position: NGOs and Development in Africa, 78 Int’l Aff. 3, 10 (2002).
 Dr. Jemima Pierre, Professor, Africa and The World: Africa and the Geopolitics of Aid and Development, Lecture at the University of California, Los Angeles (Mar. 9, 2017).
 Manji & O’Coill, supra note 39, at 10.
 Id. at 11.
 Id. at 10.
 Id. at 9.
 See id. at 2.
 See generally id.
 Pierre, supra note 23.
 See id.
 Gellar, supra note 19, at 132.
 See Maldar, supra 50.
 See id.
 See id.
 See id.
 Sola Odunfa, Nigeria: Burning with rage, BBC World Serv. (Dec. 14, 2006), http://www.bbc.co.uk/worldservice/africa/features/focus_magazine/news/story/2006/05/printable/060515_nigeriadelta.shtml.
 Andrew Rowell & Stephen Kretzmann, All for Shell: The Ogoni Struggle – A Project Underground Report, Yale Law Sch. Lowenstein Project (Nov. 1, 1996), https://web.archive.org/web/20141221075050/http://www.ratical.org/corporations/OgoniStruggleTL.html.
 See id.
 See John Vidal, Shell oil paid Nigerian military to put down protests, court documents show, Guardian (Oct. 2, 2011), https://www.theguardian.com/world/2011/oct/03/shell-oil-paid-nigerian-military.
 See Wiwa v. Shell Petroleum Dev. Co. of Nigeria, 335 F. App’x 81, 82-83 (2d Cir. 2009); Ctr. for Constitutional Rights, Wiwa v. Royal Dutch Petroleum, https://ccrjustice.org/home/what-we-do/our-cases/wiwa-et-al-v-royal-dutch-petroleum-et-al;Vidal, supra note 72.
 Wiwa v. Royal Dutch Shell—Getting Away with Murder: Shell’s Complicity with Crimes Against Humanity in Nigeria, EarthRights Int’l, https://earthrights.org/case/wiwa-v-royal-dutch-shell/ (last visited Oct. 25, 2020); Vidal, supra note 72.
 Constitution of Nigeria (1999), § 215.1(a).
 Id. at § 215.1(3).
 E.g., Nigeria’s Lagos shut down after at least 12 protesters killed by army and police, CBS News (Oct. 22, 2020), https://www.cbsnews.com/news/nigeria-lagos-shut-down-protesters-killed/.
 Constitution of Nigeria (1999), § 130.2.
 See, e.g., Somto Okonkwo (@MrSomtoOkonkwo), Twitter (Oct. 23, 2020),
 Oma Djebah, National Security and The Appointment National Security Adviser, Sahara Reporters (Apr. 22, 2017), http://saharareporters.com/2017/04/22/national-security-and-appointment-national-security-adviser-oma-djebah.
 Compare Nigeria: Killing of #EndSARS protesters by the military must be investigated, Amnesty Int’l (Oct. 21, 2020), https://www.amnesty.org/en/latest/news/2020/10/killing-of-endsars-protesters-by-the-military-must-be-investigated/ (calculating the death toll at fifty-six), with BBC News, Muhammadu Buhari: President Buhari confam say #EndSARS violence kill 69 afta “Lekki toll gate Lagos” shooting (Oct. 23, 2020), https://www.bbc.com/pidgin/tori-54666307 (calculating, in West African Pidgin English, the death toll at sixty-nine).
 Noam Chomsky – History of US Rule in Latin America, YouTube (Dec. 15, 2009), https://www.youtube.com/watch?v=NKwJI9axblQ (discussing U.S. foreign policy and how generally it is a reflection of U.S. economic interests).
 Seun Kuti (@bigbirdkuti), Home Sessions End SARS or End Oppression, Instagram (Oct. 6, 2020), https://www.instagram.com/tv/CGAFtGngc3B/?igshid=lyh5z1s6i4tb.
 See Brent Radcliffe, How Economic Sanctions Work, Investopedia (June 25, 2019),
 End Swat, supra note 7.
 JR Thorpe, 3 Places To Donate To Help #EndSARS Protestors, Bustle (Oct. 22, 2020), https://www.bustle.com/life/where-to-donate-end-sars-protesters.