Another reason to love New York State Attorney General Elliot Spitzer. But, as we've said before regarding a similar case, getting Emmanuel Constant for mortgage fraud is kind of like nailing Hitler for tax-evasion. From Newsday, July 7:

A Queens man and former Haitian paramilitary leader, convicted of the 1994 massacre of slum-dwellers loyal to former Haitian President Jean-Bertrand Aristide, has been arrested and charged with committing mortgage fraud from the Melville brokerage where he works, Suffolk officials said yesterday.

Emmanuel Constant, of 137-35 225 St. in Laurelton, was arrested Wednesday and will be arraigned in Suffolk today before Acting State Supreme Court Justice Michael Mullen on charges of first-degree grand larceny, falsifying business records and forgery, Suffolk district attorney's office spokesman Robert Clifford said.

The case is being prosecuted by the state attorney general's office. Clifford said details of the charges against Constant were not available late yesterday. Officials at the state attorney general's office could not be reached for comment.

Constant did not return a call to his office at New York Mortgage Co. LLC in Melville. When called at his home, a woman who identified herself as Constant's wife said she did not know anything about the charges and that her husband was "upstairs sleeping."

Constant has lived in New York since 1995, despite a deportation order and charges that he led the Haitian paramilitary group, the Front for the Advancement and Progress of Haiti, during the mid-1990s. Human rights groups allege the group terrorized and slaughtered supporters of the toppled Aristide.

After U.S. forces helped restore Aristide to power, Constant slipped into the United States on a tourist visa. Immigration and Naturalization Service agents captured him in Queens, but Constant appealed his deportation on the ground he would be killed if sent back.

He was released in 1996 on the condition that he not travel outside New York City and that he report regularly to the INS, now called Immigration and Customs Enforcement.

In 2000, a Haitian court sentenced Constant to life in prison following his conviction in absentia for the 1994 massacre.

In a 2005 federal lawsuit, three unnamed women now living in the United States said Constant's soldiers engaged in a "systematic campaign of violence against women" under his rule, and beat and gang-raped them.

Constant has so far largely ignored the lawsuit, the women's lawyers have said.

See our last posts on Haiti and Emmanuel Constant.