Burnley v. U.S.: Demanding Accountability on Caribbean Boat Strikes

On October 14, 2025, the United States government authorized and launched a missile strike that killed Chad Joseph and Rishi Samaroo, two Trinidadian men who were traveling by boat from Venezuela to their homes in Trinidad and Tobago.

Before the United States killed him, Mr. Joseph lived with his wife and their three children in Las Cuevas, Trinidad. To support his family, he often traveled to Venezuela to fish and for farmwork. On October 12, he called his wife to let her know that he had found a boat ride home from Venezuela and would see her in a couple of days. On October 14, his wife and mother saw social media reports of a boat strike; fearing that the boat was his, they repeatedly called him but got no reply. His family has not heard from him since.

Like Mr. Joseph, Mr. Samaroo was working on a farm in Venezuela in the weeks before his death, taking care of goats and cows and making cheese. In an October 12 call with his sister, he told her he was returning home to Trinidad and would see her in a few days because their mother had fallen ill, and he wanted to help take care of her. That was the last time Ms. Korasingh or anyone else in the family heard from him.

The October 14 attack that killed Mr. Joseph and Mr. Samaroo was part of an unprecedented and manifestly unlawful U.S. military campaign of lethal strikes against small boats in the Caribbean and eastern Pacific Ocean. These premeditated and intentional killings—carried out outside of the context of armed conflict and in circumstances where targeted individuals do not pose a concrete, specific, and immediate threat of grave harm—violate domestic law prohibiting murder and international law prohibiting extrajudicial killing, or the arbitrary or unlawful deprivation of the right to life.

Through this lawsuit, Plaintiffs Lenore Burnley, Mr. Joseph’s mother, and Sallycar Korasingh, Mr. Samaroo’s sister, are demanding accountability for their loved ones’ deaths. Their lawsuit asserts claims under two federal statutes that entitle Mr. Joseph’s and Mr. Samaroo’s survivors to compensation and redress: the Death on the High Seas Act, which establishes a cause of action for wrongful deaths occurring on the high seas, and the Alien Tort Statute, which permits non-citizens to bring suit in U.S. courts for violations of international law, including the prohibition on extrajudicial killing.