The Spanish example was both - engine behind and bearer of all hope of legal developments and reform as Spain acted as an agent for other European states conducting criminal investigations which are as necessary as are impossible in other states for legal and political reasons. Confronted with upcoming harsh critique the Spanish model is threatened to fail, which might further deligitimize the criminal prosecution of human rights violations or even the entire discourse on human rights.

A delicate job for Obama: the judicial refurbishment of the Bush era. When President Bush resigns from office he will not only pass on internal and external politicl problems to his successor but also a delicate legal legacy.