Extrajudicial Killings: A Case Study of the U.S. Boat Strikes

By Dana A. Wakeman

Dana Wakeman, a May 2026 graduate of Albany Law School, was the Editor-in-Chief of Albany Law Review, Volume 89. During her time in law school, Dana interned twice in the Northern District of New York for two different judges, as well as with the United States Government Accountability Office. Dana was also selected as a Teaching Assistant for Torts, Constitutional Law I, and Constitutional Law II classes.

Prior to law school, Dana earned her Master's in Public Administration from American University and her Bachelor of Arts in Political Science from Siena University. While in graduate school, Dana worked for a research consulting firm, which also included presenting at the 2023 American Association for Public Opinion Research Conference. During her time at Siena, Dana participated in the Bonner Service Leaders Program, culminating in 2,500 hours of community service as well as a community engaged thesis project on drug diversion programs.

Dana has two forthcoming publications in Albany Law Review including “Setting a Higher Bar: Reforming Presidential Immunity” and “What's Next: Expanding State Constitutional Independence in New York.”  In April 2026, Dana's article entitled "Amy Coney Barrett: Carving Her Own Path on the Court" was published by the Center for Judicial Process.

Dana is currently serving as an Assistant Appellate Court Attorney at the New York State Appellate Division, Third Department.

In 2025, President Donald Trump ordered strikes on boats operated by alleged drug traffickers off the shore of Venezuela. Those striks together killed over eighty people. The strikes garnered significant criticism as extrajudicial killings, and their legality has been called into question by legal experts. This paper explores the definition of extrajudicial killings, as well as the available methods to provide legal accountability for them.

One method of legal accountability is carried out by international actors or the International Criminal Court. Another method is national accountability that could be carried out via Congressional power.  This paper argues that it is crucial for international and domestic actors to hold the United States accountable for its boat strikes, especially to hinder future similar volatile actions.

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