On the 10th anniversary of the 709 Crackdown, 9 July 2025, ALN is releasing an article reflecting on the legacy of the 709 Crackdown and 10 years of repression against lawyers in China.

The Legacy of the 709 Crackdown: A Decade of Repression Against Lawyers in China

9 July 2025

July 9th, 2025 (7/09) marks the tenth anniversary of the 709 Crackdown, the Chinese government’s coordinated campaign of suppression, persecution, and intimidation against human rights lawyers, legal staff, and activists.[1] Prominent rights lawyers were arrested and incarcerated, and many were convicted of serious crimes like subversion of state power.[2] In addition, over three hundred people were temporarily detained and interrogated.[3] The treatment of people impacted by the 709 Crackdown constitutes serious violations of international law. The crackdown was motivated by the government’s desire to exert greater control over lawyers, whose activism and advocacy were seen as a threat to social stability and the political control of the Chinese Communist Party (CCP). Since the initial wave of arrests in 2015, the format of repression has evolved. The government reduced reliance on the criminal justice system. Instead, it has turned to extrajudicial harassment of rights lawyers and their families and the weaponization of administrative rules governing licensing. We urge the international community to pressure the Chinese government to stop terrorizing the legal community and to cease the arbitrary detention and harassment of lawyers like Wang Yu, who are still suffering from extrajudicial harassment long after their official release from detention.

I. Introduction

A.   Impact and legacy of the crackdown

The 709 Crackdown has had a serious chilling effect on human rights lawyering in China.[4] The crackdown sent the message that advocacy will result in disappearance, torture, criminal charges, and endless harassment even after release, creating a powerful disincentive. Moreover, the 709 Crackdown had focused on lawyers and activists representing disadvantaged groups such as criminal defendants, persecuted religious minorities, and victims of government or corporate abuses of power.[5] Given the power imbalances present in those cases, lawyers often resorted to judicial activism outside the courtroom, such as publicizing the case on social media and organizing demonstrations and protests in collaboration with activists.[6] The Chinese government opposes such lawyer-activist cooperation because it constitutes a form of civil society organization outside official control.[7] These judicial activist tactics also challenge the government’s official media narrative and are feared to result in further civil unrest, which explains the government’s labeling of these activities as “picking quarrels and provoking troubles.” [8]

B.   Categories of Rights Violations

The 709 Crackdown perpetrated serious human rights violations, which are discussed in more detail in the sections below. The most grievous violation of international law is the government’s use of torture and forced disappearance. The crackdown also violated the civil and political rights of lawyers and activists. Moreover, rights violations occurred against the victims’ families, who were the targets of extreme harassment despite being completely innocent. Finally, the crackdown imperils the civil and political rights as well as the economic and social rights of all Chinese people.

II. The Background of the 709 Crackdown

A.   The start of the crackdown on 9 July 2015

In the early morning of 9 July 2015, human rights lawyer Wang Yu was taken from her home after police suddenly cut off electricity and internet access.[9] She is a tenacious human rights lawyer affiliated with the Fengrui law firm in Beijing and has worked on numerous politically sensitive cases, such as representing Falun Gong practitioners, Uyghur rights activist Ilham Tohti, and victims of sexual assault.[10] Wang’s disappearance marked the beginning of the 709 Crackdown. In the short span of the next several days, over two hundred lawyers, activists, and law firm staff were detained and questioned by police.[11] The total number of victims would grow to over three hundred.[12] Sixteen would be convicted of serious crimes such as “subversion of state power” or “picking quarrels and provoking trouble.”[13] Seventeen others were charged with these crimes but released before trial.[14]

The speed and scale of the crackdown generated an instant chilling effect across the Chinese legal community. The number of people targeted vastly exceeded the previous crackdown in 2011, which saw fifty-four people detained.[15] The crackdown was coordinated and ruthlessly systematic. As the arrests began, a cyberattack knocked out messaging apps used by activists, sowing panic and confusion.[16] The police also raided the offices of major human rights law firms like Fengrui, further throwing the community into chaos.[17] Activists and lawyers felt shock and horror as people they knew and worked with disappeared one after another, all while dreading that they might be next.[18]

Wang was detained at a secret location without access to legal representation for over a year.[19] In January 2016, she was charged with “subversion of state power” and in August 2016, she was released on bail after appearing in a video repudiating her prior legal work, stating that Fengrui lawyers were trained by foreign organizations to tarnish China’s reputation.[20] In subsequent interviews and statements, Wang explained she had been coerced by threats to her young son.[21] Even after her release, harassment and intimidation continued. Wang and her family were forcibly relocated to Ulanhot, Inner Mongolia and kept under constant surveillance.[22]

B.   Focus on a Fengrui-Led "Conspiracy"

Among the victims who were criminally charged, a large contingent was affiliated with the Fengrui law firm, which was a prominent hub of rights activism. Founded in 2007 by Zhou Shifeng, Fengrui lawyers were at the forefront of fighting for justice on behalf of political dissidents, criminal defendants, and religious minorities.[23] The firm had represented activist Ai Weiwei, Falun Gong practitioners, and victims of contaminated baby formula.[24] Several lawyers at the firm were arrested and disappeared, including Wang Yu, Zhou Shifeng, and Wang Quanzhang.[25] In addition to veteran lawyers, two trainee lawyers, an administrative assistant, and accountant who worked at Fengrui were also detained for months.[26] That is evidence of the government’s intent in totally dismantling Fengrui and thus destroy a central institution in the activist community.

State media portrayed Fengrui as the center of a criminal network that sabotaged the justice system and undermined the government.[27] Lawyers and activists who were not a part of Fengrui were nonetheless woven into this broader narrative of a Fengrui-led conspiracy. For example, another veteran rights lawyer Li Heping, who was a partner at a different law firm, was accused of using Fengrui as a platform to coordinate his activities.[28] Similar accusations were levied against activists Gou Hongguo and Zhai Yanmin.[29]

C.   Motivations for the 709 Crackdown

1.    The development of extrajudicial activism tactics by rights lawyers

The 709 Crackdown targeted lawyers representing clients from disadvantaged groups and the victims of government and corporate abuses of power. China’s legal environment and the institutional barriers to accessing justice are critical to understanding the 709 Crackdown. The crackdown was the government’s reaction to rights lawyers’ innovative methods of seeking justice for their clients. Rights lawyers confront formidable barriers. In criminal cases, lawyers are constantly denied access to their clients, witnesses, and the prosecution’s evidence.[30] China’s conviction rate is astoundingly high (99.93% in 2014), indicating a lack of substantive presumption of innocence.[31] Defendants are coerced to confess by torture and defense lawyers are often blocked from presenting evidence of such torture in court.[32] In civil cases, courts can block certain suits from being filed and exclude certain arguments.[33] Officials also pressure plaintiffs and lawyers to drop cases that could embarrass the government. For example, lawyers representing parents of children injured by contaminated milk powder were repeatedly warned not to sue.[34]

In response, rights lawyers like Wang Yu increasingly resorted to activism outside the courtroom. First, rights lawyers used social media to publicize details about their cases and to highlight rights abuses. For instance, lawyers posted photos of their injuries after being beaten while trying to meet with their clients.[35] A popular slogan among activist lawyers was “[w]atching is a kind of power too (围观也是一种力量).”[36] Second, lawyers published videos that explained events from the perspective of their clients to generate public sympathy and support.[37] Lawyers would interview clients and their loved ones to illustrate how they were victimized by poverty and abusive government policies.[38] Third, lawyers organized sit-ins and protests to draw attention to rights abuses. In one case, lawyers of men falsely convicted of murder staged a two-week long sit-in at the local courthouse.[39] Another example is Wang Yu organizing a street protest to draw attention to six victims of sexual assault, whom she was representing.[40]

Finally, lawyers started banding together and collaborating with activists, academics, and journalists. Rights lawyers who worked on similar cases formed associations to assist each other and amplify their voices.[41] At the same time, lawyers formed working relationships with journalists, who provided extra media coverage.[42] Lawyers also worked with activists to organize protests. Some activists were known for taking provocative stances. Wu Gan, who often collaborated with lawyers at the Fengrui law firm, posted photoshopped images of provincial officials as pigs and protested outside the courthouse holding a banner containing an image of a judge caricatured as Hitler to protest four men’s wrongful murder conviction.[43]

2.    The threat posed by extrajudicial activism to the Chinese government

Rights lawyers’ tactics were proving to be successful. For instance, the four men convicted of murder who were the target of Wu Gan’s protests were re-tried, acquitted, and received compensation.[44] It is very rare for a conviction to be reversed. However, the Chinese government viewed extrajudicial activism as a threat to government control over civil society and a cause of social unrest. The core motivation behind the 709 Crackdown was fear that rights lawyers’ activism will draw attention to deeper structural problems like corruption, stoking popular anger against the ruling Chinese Communist Party.[45] Under Xi Jinping’s leadership, national security has become an all-encompassing concern. Government security forces extinguish any activities or discourse that could weaken the legitimacy or authority of the Chinese Communist Party (CCP).[46] This is supported by the official narrative of the crackdown promoted by state media outlets and prosecutors, which painted rights lawyers as a threat to national security. In July 2015, Xinhua News emphasized the coordinated nature of the law firms and accused the arrested lawyers of “rabble-rousing” and promoting “mob rule.”[47] Arrested lawyers would typically be charged with “picking quarrels and provoking troubles” or “inciting subversion of state power.” [48] At the trial of Zhou Shifeng, the founder of the Fengrui law firm, prosecutors emphasized that he spread subversive ideas that “discredit[ed] the government” and “damage[d] national security.”[49]

Control over the legal community became more important in light of reforms that increased the independence and professionalism of judges.[50] In 2014, China’s highest court announced a major reform package aimed at making the justice system more stable, predictable, and transparent.[51] Judge appointments would become more meritocratic and local governments’ ability to interference with decision making would be curtailed.[52] However, policymakers did not want these more independent courts to become a way for lawyers to check government power.[53] As the government ceded some control over judges, it used the 709 Crackdown to assert more control over lawyers. The 709 Crackdown was one indication that the government’s legal reforms would not extend to cases that are politically sensitive or involve the state, like criminal cases.[54] Instead, reforms were primarily intended to promote sustained economic development by providing an impartial way to resolve contract, investment, and intellectual property disputes.[55]

III. Weaponization of the Criminal Justice System

In the initial stages of the 709 Crackdown, the Chinese government primarily utilized the criminal justice system to silence rights lawyers and activists. These lawyers’ experiences also set examples to intimidate the entire legal community. The possibility of being disappeared for an unknown period of time, being subject to torture, and cut off from all contact with family and friends, is a potent threat. The threat is reinforced by the government’s decision to charge prominent lawyers and activists with subversion of state power, which carries a possible sentence of life imprisonment.[56] The chilling effect of the crackdown extended even to law students, pushing them to pass up courses in human rights.[57]

The methods used by the government are gross violations of the accused lawyers’ civil and political rights. The most severe violation is the use of enforced disappearance and torture. Victims of the crackdown were detained and their locations kept secret from families and their lawyers.[58] Incommunicado detention occurred at numerous stages: before victims were charged with a crime, while awaiting trial, and after release.[59] There is widespread reports of torture, which is facilitated by the enforced disappearances.[60] Enforced disappearance and torture violate the rights to freedom from inhuman treatment and torture, which are fundamental peremptory (jus cogens) human rights all states are obligated to respect and are enshrined in the Universal Declaration of Human Rights (“UDHR,” Article 5 and 9), which constitutes customary international law, the International Covenant on Civil and Political Rights (“ICCPR,” Article 7 and 9), which the government of China has signed and which constitutes customary international law, the UN Convention Against Torture (“CAT”), which the government of China has ratified, and the International Convention for the Protection of All Persons from Enforced Disappearance (“ICPPED”), which constitutes customary international law.

The crackdown also violated the civil and political rights of lawyers and activists. First, the government deprived them of their procedural rights to a fair trial and due process by blocking their access to lawyers and holding trials in secret (UDHR Article 10 and 11).[61] Second, the government weaponized the criminal justice system to retaliate against them for their advocacy, expression, and assembly, violating their rights to these things (UDHR Article 19 and 20; Basic Principles on the Role of Lawyers, “Basic Principles” Article 16 through 22).

A.   Pre-trial detention

Immediately after their arrest, lawyers like Wang Yu were detained in secret locations under a procedure called “Residential Surveillance at a Designated Location” (RSDL).[62] Police can detain suspects under RSDL for up to six months, during which the victim is completely cut off from outside contact, including with family and legal counsel.[63] After the six-month period expired, authorities extended the length of detentions by shuttling victims to different detention centers and registering them under fake names to prevent their family members from locating them.[64] In a particularly egregious case, Fengrui lawyer Wang Quanzhang was detained incommunicado under a fake name for over three and a half years.[65] Such detentions occur prior to any criminal charges, have no basis in law, and constitute enforced disappearances.

B.   Torture

Torture is endemic among detained lawyers in China and widely reported by victims after release. Wu Gan and Wang Yu both reported being subject to sleep deprivation and shackled for long periods of time while in detention.[66] Lawyers Wang Quanzhang and Li Heping described being subject to electric shocks.[67] There is also evidence of detainees being force-fed medication that produced serious biomedical harms like muscle pain and mental impairment.[68] Other reported instances of torture include beatings, prolonged interrogations, and being forced to assume painful positions for long periods of time.[69] The use of torture has persisted to the present day. Rights lawyers Lu Siwei and Xu Zhiyong continue to be subject to torture in prison, with Lu Siwei being denied medical treatment and adequate nutrition and Xu Zhiyong conducting a hunger strike in November 2024 to protest the inhuman conditions of his detention.[70]

Moreover, there is a close link between torture and incommunicado detention, such as RSDL. Furthermore, complete isolation is itself cruel for the detained and the uncertainty is emotionally traumatic for their loved ones. Victims were kept under constant surveillance by guards with little privacy.[71] One activist described being forbidden to speak or even move without permission from guards.[72] Isolation also facilitates torture by preventing public scrutiny and providing time for signs of torture to fade.[73]

C.   Post-release detention

Even after a rights lawyer or activist is formally released, either because of a plea bargain, having posted bail, or the completion of her sentence, she could continue to be detained or kept under tight surveillance. This system is also known as “non-release release (NRR).”[74] The form of detention ranges from incommunicado incarceration that is very similar to RSDL, to house arrest, to heavy surveillance.[75] Some activists were kept for several weeks in NRR, while others were held for years. One example is Wang Yu, who was placed under house arrest with her family in Ulanhot, Inner Mongolia for six months even though she had been released following her confession and was not convicted of any crime.[76] Her residence in Ulanhot was kept under tight surveillance and she was not allowed access to the internet.[77]

NRR enables the government to isolate rights lawyers from family, friends, and media outlets, preventing the exchange of information about any mistreatment during the victim’s incarceration.[78] NRR adds an extra layer of trauma to victims and their families by subverting their hopes and expectations of release at a predetermined date. NRR is also used to forcibly relocate human rights lawyers from major cities to more isolated areas, where they would be less able to engage in further activism.

D.   Politically motivated criminal charges

After languishing in detention for months, if not years, over thirty victims of the 709 Crackdown were criminally charged with “picking quarrels and provoking troubles” or “inciting subversion of state power.”[79] These charges have no factual basis and are in retaliation for protected speech and assembly. They are used to intimidate the entire legal community, as subversion of state power carries a possible sentence of life imprisonment.[80] International standards provide lawyers with protections for their work. The Basic Principles declares that “lawyers shall enjoy civil and penal immunity for relevant statements made in good faith in written or oral pleadings or in their professional appearances before a court, tribunal or other legal or administrative authority” (Article 20). Furthermore, Article 35 of the PRC Constitution guarantees “freedom of speech, the press, assembly, association, procession and demonstration.” All these rights are violated by criminal charges that punish activism on behalf of clients.

E.   Violations of procedural rights to a fair trial

Victims of the 709 Crackdown also experienced violations of their procedural rights to a fair trial during their trials. First, they were denied legal representation. Authorities blocked detainees from meeting with their lawyers on national security grounds.[81] Authorities also pressured detainees to fire their lawyers and accept representation by state-appointed counsel.[82] Another tactic was to target the lawyers themselves in reprisal. Two lawyers, Li Yuhan and Yu Wensheng, were detained by authorities in 2017 and 2018 respectively and criminally charged.[83] Li and Yu had been representing lawyers arrested in the initial crackdown and their arrests sent a stark warning to the legal community against assisting victims of the crackdown.[84] State-appointed lawyers transform trials into formalities by failing to vigorously defend their clients.[85] Lawyers are also an invaluable conduit between the detainee and their families and outside media. However, government-appointed lawyers do not faithfully relay messages, and their identities are often hidden from defendants’ families.[86] A second procedural violation is holding trials in secret. The families of the accused, independent lawyers, and foreign media outlets were denied access to the trials of victims like Li Heping and Wang Quanzhang.[87] The government has used the fact that these trials implicate state secrets as excuse.[88] Secret trials make it easier for the government to hide evidence of torture and other procedural violations.

F.    Retaliation against victims’ families

One objective of the 709 Crackdown was to discredit rights lawyers and activists. Government-controlled media vilified rights lawyers as members of a “criminal syndicate” who are spreading falsehoods.[89] To further this narrative, Chinese authorities coerced detainees into “confessing” their crimes by threatening their families. The spouses and children of victims faced detention, travel bans, and harassment that blocked them from schooling, employment, and housing.[90] For example, local authorities prevented the children of lawyers Li Heping and Wang Quanzhang from enrolling in school.[91] Promises to leave their families alone became powerful leverage that coerced several lawyers like Wang Yu to provide false confessions.[92] Harassment of victims’ families are naked attempts at collective punishment and coercion.

IV. The Evolution of the Crackdown Against Lawyers

Since the waves of detentions and arrests in 2015, the Chinese government’s repression of rights lawyers has evolved to rely less on the criminal justice system. Lawyers continue to be detained and arrested, but not at the same scale as had occurred in 2015. Instead, repression has shifted towards travel restrictions, pervasive surveillance, and the weaponization of administrative regulations on licensing.  As the initial victims of the 709 Crackdown exit the formal criminal justice system after being released on bail or the completion of their sentences, they have continued to face harassment and restrictions. These practices also target the lawyers’ families, who are completely innocent. Furthermore, regulatory rules governing licensing enable the government to preemptively and systematically control the activities of all lawyers. Compared to the criminal justice system, regulatory controls are more subtle. However, they are just as effective in controlling lawyers’ behavior and cause tremendous harm to victims.

Intense campaigns of harassment that prevent rights lawyers, even after their release, from travelling and finding employment and housing constitute extrajudicial punishment that is cruel and degrading (UDHR Article 5 and 11). These restrictions violate rights lawyers and their families’ civil and political rights to freedom of movement and privacy and economic and social rights to work, housing, leisure, an adequate standard of living, and education (UDHR Article 12, 13, 23, 24, 25, 26). The extension of harassment to the families of rights lawyers imposes punishment without due process as they have not been found guilty of any crime (UDHR Articles 9, 10, and 11). Using harassment and manipulation of the licensing rules to retaliate against lawyers for their advocacy for certain clients also violates lawyers’ right to freedom of expression and relevant Basic Principles on the Role of Lawyers (UDHR Article 19 and 20, Basic Principles Articles 16 through 22).

A.   Continued harassment of 709 Crackdown victims

After 709 Crackdown victims were released from detention and imprisonment, the government has singled them out for harassment. Victims and their families are often banned from exiting the country, with national security cited as justification. However, this rationale is flimsy. Victims are given no detailed explanations and there is no due process to challenge these bans. For instance, 709 Crackdown victim Li Heping and his family were prevented from leaving the country at the airport.[93] Wang Yu also does not have a passport and is blocked from applying for one.[94] Exit bans are cruel and have prevented victims from meeting with their critically ill family members living abroad.[95] There is also no justification for extending these bans to victims’ families. Spouses, children, and even elderly parents are impacted. The parents of one rights lawyer, Jiang Tianyong, had their applications to renew their passports denied on account of their son’s work.[96]

Victims also cannot travel freely within China and are kept under constant surveillance by police.[97] The government hires people to follow them around and loiter near their home.[98] There is no transparency on the identities of these watchers or their connections to the local security forces. Rights lawyers suspect they are informal contractors affiliated with local police.[99] Sometimes, lawyers have reported being physically stopped from leaving their apartment by these groups of unidentified men.[100] Other lawyers would be detained and interrogated for hours whenever they travel to a new city (Wang Yu and Chen Jianfang).[101]

Victims and their families are also subject to pervasive harassment in areas like education, employment, and housing. State security agents pressure school officials to refuse admission to the children of victims.[102] The young daughter of Li Heping, for instance, was prevented from enrolling in school for two years between 2016 and 2018.[103] The presence of government agents unnerves landlords, leading rights lawyers to be evicted from their homes. In one instance, Wang Quanzhang was forced to move apartments 13 times.[104] Another tactic is to cut electricity to lawyers’ apartments to force them to leave.[105] Such pervasive harassment can be deeply traumatic and detrimental to the victims and their families’ economic prospects. Rights lawyers are robbed of the opportunity to lead ordinary lives.

B.   Administrative Harassment

1.    Weaponization of licensing rules

The government has used licensing rules to silence lawyers that engage in activism or handle politically sensitive cases. The Ministry of Justice revised and tightened the regulations that govern the conduct of lawyers and law firms in 2016 and 2018.[106] Regulations enshrine the guiding purpose of the legal profession as service of the Chinese Communist Party. Law firms are required to “persist in preserving the authority and uniform leadership of the Party with Comrade Xi Jinping as its core” (Article 3 of the “Measures on the Administration of Law Firms”).[107] In addition, the “Administrative Measures for the Practice of Law by Lawyers” stipulate that “lawyers shall have supporting the leadership of the Chinese Communist Party […] as the basic requirement of practice” (Article 2).[108]

Furthermore, those who are convicted of a non-negligent crime are ineligible to receive a law license.[109] Thus, the lawyers convicted of subversion of state power or provoking troubles could no longer practice law after their release. Convictions for those crimes are also accompanied by supplemental punishment of being stripped of civil and political rights. Wang Quanzhang, for example, was deprived of all rights to speech, publication, and assembly, including making statements on social media and giving interviews about his experiences.[110] Lawyers who were not formally convicted of a crime, like Wang Yu, also had their law licenses revoked.[111] These revocations make it very difficult for lawyers to support themselves and their families financially.

2.    Regulations governing law firms

Article 50 of the “Measures on the Administration of Law Firms” mandates law firms to control the activities of lawyers in their employ.[112] The list of prohibited activities reads like a point-by-point rebuttal of the strategies of rights lawyers before the 709 Crackdown.

•  Rights lawyers used social media to draw attention to rights abuses committed by the government. Article 50.6 bans “disseminating speech denying the fundamental political system […] established by the Constitution” and “exploit the networks and media to provoke dissatisfaction with the Party and government.”[113] No criticisms of the government would be allowed.

• Rights lawyers created their own documentaries explaining their clients’ plight. Article 50.2 bans “conduct distorting or misleading publicity and commentary on cases that they or other lawyers are currently handling.”[114] Pushback against the official media narrative is prohibited.

• Rights lawyers worked with activists to stage protests in front of courthouses, drawing in members of the public. Article 50.1 prohibits “using instigation, incitement, or organizing of parties or other persons to go to judicial organs […] for sit-ins.”[115] Article 50.3 condemns “creating pressure from public opinion” and Article 50.5 bans “gathering crowds to make a ruckus or charge the courtroom.”[116]

3.    Regulations governing lawyers

The “Administrative Measures for the Practice of Law by Lawyers” contains very similar restrictions on individual lawyers.

• Lawyers cannot use “improper methods” to influence cases (Article 38) or “obstruct or disrupt the normal conduct of litigation” (Article 39).[117]

• Lawyers cannot disseminate “distorting or misleading publicity and commentary on cases.” Such behavior is deemed “maliciously stirring up the case” (Article 38). [118]

• Lawyers are forbidden to “instigate, incite, and organize” collective action in front of government buildings (Article 37).[119] This provision is noteworthy for its broad restrictions targeting any kind of collective action, even if the group was merely “vocalizing support” or “looking on.”

• Lawyers are prohibited from “creating pressure from public opinion” and “attacking or disparaging […] the justice system” (Article 38).[120] Lawyers cannot “align groups,” which would encompass all forms of coalition building with other civil society organizations (Article 38).[121]

4.    License revocation, suspension, and renewal as enforcement mechanisms

The Bureau of Justice, a subsidiary branch of the Ministry of Justice, oversees the licensing of lawyers.[122] Lawyers who fail to abide by the administrative measures can have their licenses revoked.[123] Licenses can also be suspended for up to a year.[124] Theoretically, suspended licenses can be reinstated. However, in practice, reinstatement requests are always denied for rights lawyers.[125] Licenses can also be revoked via the annual renewal process. Lawyers must undergo an annual performance review, which certifies that they are qualified to practice. Activism and taking on politically sensitive cases can be justifications for judging a lawyer unqualified, causing her license to expire.[126] There is no independent appeals body for the Bureau of Justice’s decisions. [127] Notably, several lawyers who attempted to represent victims of the 709 Crackdowns had their licenses revoked in retaliation, such as Wen Donghai, who had represented Wang Yu.[128]

The government’s control over law firms cements its control over lawyers. Law firms also must be licensed and failing to discipline lawyers for violating the administrative measures is grounds for license revocation.[129] Law firms are also subject to an annual evaluation and the process can be deeply intrusive. For example, in 2017, local authorities launched investigations into seven law firms.[130] Officials interviewed employees about cases that the firm worked on, reviewed the firm’s contracts and receipts, and investigated lawyers’ online speech.[131] Moreover, one criterion of the evaluation is whether the firm “adhered to the Constitution and laws [and] carried out their legal obligations and managed themselves responsibly.”[132] The annual review process is thus a formal way for authorities to sanction firms that do not clamp down on their employees. Without a license, it is significantly harder for firms to retain clients. In effect, the government can outsource some of its repression to firms. The threat of revocation forces firms to preemptively discourage and prevent lawyers from taking actions that would violate the administrative measures. The government also has leverage to coerce firms into firing lawyers who work on sensitive cases.[133] Failing to work for six consecutive months at a law firm automatically entails a year-long license suspension.[134] This allows the government to suspend a lawyer’s license indirectly by preventing her from being hired by law firms.

Between the 709 Crackdown in 2015 and February 2023, 46 lawyers and 3 law firms have had their licenses suspended or revoked.[135] The chilling effect, however, far exceeds the raw number of revocations. The licensing process is rife with procedural violations and highly opaque. Lawyers do not receive proper written notifications from the Bureau of Justice regarding its decisions, nor are they given a detailed explanation.[136] There is also no impartial appeals process.[137] Administrative measures are yet another threat that looms over all lawyers. Licensing impacts lawyers’ livelihoods and their ability to practice their life’s passion. The government does not need to invoke these measures frequently to make all lawyers think twice before advocating for a particular client.

V. Rights Lawyering in China Today: Challenges, Adaptation, and Resilience

The 709 Crackdown dealt a heavy blow to human rights activism in China and created an atmosphere saturated with fear.[138] Engaging in activism could bring horrific consequences, from incarceration to seemingly never-ending harassment. The decision to lock up even trainee lawyers, paralegals, and staff, many of whom were very young, was an especially strong deterrent.[139] The chilling effect caused many activists to flee into exile or give up advocacy.[140]

Another important consequence of the crackdown is the destruction of cohesion within the activist community. Veteran rights lawyers were jailed for many years and found themselves muzzled by disbarment and restrictions even after release. They can no longer participate in advocacy, depriving the movement of leadership and expertise. Previous centers of rights lawyering, the law firms like Fengrui, were shuttered.[141] Furthermore, the government has continued to crack down whenever lawyers and activists attempt to coordinate or band together. One example is the Xiamen gathering in 2019, where lawyers and activists met to discuss human rights and democratic transition.[142] Every participant, more than twenty in all, were either arrested or forced into exile.[143]

The 709 Crackdown also cascaded outward from the initial victims, where lawyers defending the previous victims became the next targets. One such chain originated from Wang Yu, the very first lawyer to disappear in July 2015. Li Yuhan, a lawyer who attempted to represent Wang Yu during her disappearance, was arrested in 2017.[144] Lin Qilei, who represented Li Yuhan, in turn had his license revoked in 2021.[145] The rights lawyering community was thus shattered by the 709 Crackdown. Advocates and lawyers had to fear for the safety of themselves and their families alone and atomized, unable to organize or defend each other.

A.   A turn away from politically sensitive cases

The massive suppression of rights lawyers and activists has been devastating for human rights in China. Many kinds of cases have become taboo. Lawyers in China describe the creation of a zone of politically sensitive cases that they hesitate to accept.[146] These include cases involving ethnic or religious minorities, and, more broadly, cases that would uncover facts unfavorable to the government or incite popular unrest.[147] What may constitute a politically sensitive topic is not clearly defined. By raising the stakes, the 709 Crackdown has made lawyers less willing to take on even those cases that might be sensitive.[148]

This is a major erosion of civil and political rights of all Chinese people. People who find their dispute falling into that category of “politically sensitive” become stripped of legal representation. The rights to equal protection of the law and an effective legal remedy are enshrined in the UDHR (Article 7 and 8), ICCPR (Article 26), and the Basic Principles (Article 1 through 3). Moreover, the loss of independent lawyers removes an important mechanism of stopping government and corporate abuses of power. This weakens safeguards in a wide range of issues including environmental protection, consumer protection, public safety, land rights, and labor rights. The crackdown thus indirectly threatens the economic and social rights of all Chinese people across virtually every area. These rights are enshrined in the International Covenant on Economic, Social and Cultural Rights, “ICESCR” (Article 7, 11, 12, 13), which the government of China has ratified.

Some legal advocacy remains intact in China, primarily in criminal defense.[149] However, to adapt, criminal defense lawyers avoid direct criticisms of the government. They also turn down cases that might implicate national security.[150] Instead, they publicly pledge loyalty to the regime and frame their advocacy as targeting individual instances of wrongdoing by local police or judges, as opposed to systemic issues with the entire justice system.[151] The narrative these lawyers craft is that they point out local abuses of power so the central government can take notice and receive credit for fixing the problem. While it is heartening that lawyers can continue to zealously advocate on behalf of some criminal defendants, the forms of advocacy that remain are much more limited. The scope of cases that lawyers are willing to take has shrunk and lawyers’ room to honestly and openly critique structural issues has narrowed.

VI. Conclusion

The 709 Crackdown was a watershed moment in the Chinese government’s suppression of human rights lawyers and activists. It has severely damaged the rule of law in China and caused tremendous harm to the victims and their families. Giving voice to the dispossessed and helping clients vindicate their legal rights are not crimes. However, the Chinese government has been unrelenting, coming up with new mechanisms to silence and intimidate lawyers. At the tenth anniversary of this tragic event, we call on the international community to pressure the Chinese government to cease its assault on rights lawyers. The Chinese government needs to stop the use of torture against detainees, abolish its systems of pre-trial and post-release incommunicado detention, and grant defendants a fair and open trial. Furthermore, its inhumane practice of collective punishment and harassment of victims’ families must end. We also urge the international community to pressure the Chinese government to roll back its weaponization of licensing rules to silence lawyers and law firms. Finally, we ask the international community to shine a spotlight on the plight of victims like Wang Yu, Li Heping, Wang Quanzhang, and many others, who continue to experience onerous restrictions on their daily lives.

__________

[1] Human Rights in China (HRIC), “Mass Crackdown on Chinese Lawyers, Defenders and International Reactions: A Brief Chronology”, 15 Sep. 2017, https://www.hrichina.org/en/mass-crackdown-chinese-lawyers-defenders-and-international-reactions-brief-chronology.

[2] HRIC, “Fifth Anniversary of 709 Crackdown: Updated Chart of Persecution of Lawyers and Legal and Rights Advocates”, 9 Jul. 2020, https://www.hrichina.org/en/fifth-anniversary-709-crackdown-updated-chart-persecution-lawyers-and-legal-and-rights-advocates.

[3] Joyce Huang, “China Lawyer Crackdown Enters 6th Year with Fears for the Same Fate in Hong Kong”, Voice of America News, 8 Jul. 2020, https://www.voanews.com/a/east-asia-pacific_china-lawyer-crackdown-enters-6th-year-fears-same-fate-hong-kong/6192434.html.

[4] Hualing Fu and Han Zhu, “After the July 9 (709) Crackdown: The Future of Human Rights Lawyering”, Fordham International Law Journal ,14 Aug. 2018, https://ir.lawnet.fordham.edu/ilj/vol41/iss5/3/.

[5] Carrie Gracie, “Rule of law in China, a country which locks up its lawyers”, BBC, 13 Jul. 2015, https://www.bbc.com/news/world-asia-china-33502955.

[6] Tomoko Ako, “Why Is China Muzzling Its Lawyers?”, The Tokyo Foundation, 1 Feb. 2016, https://www.tokyofoundation.org/research/detail.php?id=331.

[7] Terence C. Halliday, “Gagging the Lawyers:  China’s Crackdown on Human Rights Lawyers and Its Implications for U.S.-China Relations”, Hearing of the Congressional-Executive Commission on China, 28 Jun. 2017, https://www.congress.gov/115/chrg/CHRG-115hhrg26342/CHRG-115hhrg26342.htm.

[8] Jacques deLisle, “Xi Jinping’s Impact on China’s Legal Development: Domestic and International”, The ASAN Forum, 15 Oct. 2015, https://theasanforum.org/xi-jinpings-impact-on-chinas-legal-development-domestic-and-international/.

[9] Tom Phillips, “The case of Wang Yu, emblem of China's human rights crackdown”, The Guardian, 2 Sep. 2015, https://www.theguardian.com/world/2015/sep/02/the-case-of-wang-yu-emblem-of-chinas-human-rights-crackdown.

[10] Yaxue Cao and Yaqiu Wang, “14 Cases Exemplify the Role Played by Lawyers in the Rights Defense Movement, 2003–2015”, China Change, 19 Aug. 2015, https://chinachange.org/2015/08/19/14-cases-exemplify-the-role-played-by-lawyers-in-the-rights-defense-movement-2003-2015/.

[11] Amnesty International, “China: Lawyers and activists detained or questioned by police since 9 July 2015 (as of 4.30pm Beijing time, 7 December 2015),” 7 Dec. 2015, https://www.amnesty.org/en/documents/asa17/3016/2015/en/.

[12] Chinese Human Rights Defenders (CHRD), “Individuals Affected by July 9 Crackdown on Rights Lawyers,” 28 Jan. 2019, https://www.nchrd.org/2015/07/individuals-affected-by-july-10-crackdown-on-rights-lawyers/.

[13] Human Rights in China, supra, note 2.

[14] Id.

[15] Edward Wong, “China: 54 Detained in Crackdown,” New York Times, 15 Apr. 2011, https://www.nytimes.com/2011/04/16/world/asia/16briefs-ART-china.html.

[16] Alex Palmer, “‘Flee at Once’: China’s Besieged Human Rights Lawyers,” New York Times Magazine, 25 Jul. 2017, https://www.nytimes.com/2017/07/25/magazine/the-lonely-crusade-of-chinas-human-rights-lawyers.html.

[17] Id.

[18] Id.

[19] Reuters, “China accuses prominent rights lawyer of inciting subversion”, 7 Aug. 2015, https://www.reuters.com/article/2015/08/07/us-china-rights-idUSKCN0QC1AO20150807/.

[20] Id.

[21] Epoch Times, “Wáng yǔ lǜshī zhuānfǎng: Nà tiáo zhìjīn wèi yùhé de shāngkǒu [Exclusive interview with lawyer Wang Yu: The wounds that remain unhealed]”, 29 May 2018, https://www.epochtimes.com/gb/18/5/28/n10434103.htm.

China Change, “‘My son is everything to me’: how China forced lawyer Wang Yu to denounce her human rights award”, Hong Kong Free Press, 13 May 2018, https://hongkongfp.com/2018/05/13/son-everything-china-forced-lawyer-wang-yu-denounce-human-rights-award/.

[22] Id.

[23] The Guardian, “Chinese lawyer who exposed baby milk scandal jailed for subversion,” 4 Aug. 2016, https://www.theguardian.com/world/2016/aug/04/chinese-lawyer-who-exposed-baby-milk-scandal-jailed-for-subversion.

[24] Id.

[25] CHRD, supra, note 12.

[26] Id.

[27] Amnesty International, “China: Lawyers face 15 years in jail on ‘chilling’ state security charges,” 16 Jul. 2015, https://www.amnesty.org/en/latest/news/2015/07/china-lawyers-16-july/

[28] CHRD, “Li Heping Profile,” 11 Aug. 2015, https://www.nchrd.org/2015/08/prisoner-of-conscience-li-heping/.

[29] CHRD, “Gou Hongguo Profile,” 22 Jan. 2016, https://www.nchrd.org/2016/01/gou-hongguo/; CHRD, “Zhai Yanmin Profile,” 27 Jul. 2016, https://www.nchrd.org/2016/07/zhai-yanmin/.

[30] Jibin Sun, “How "Three Difficulties" of Criminal Defense Became ‘10 Difficulties’”, Legal Weekly, 20 Jan. 2011, https://www.duihuahrjournal.org/2011/02/translation-how-three-difficulties-of.html.

[31] Eva Pils, “The Party’s Turn to Public Repression: An Analysis of the ‘709’ Crackdown on Human Rights Lawyers in China”, China law and society review, 17 Aug. 2018

[32] Id.

[33] Id.

[34] Chris Buckley, “China milk victim lawyers say pressed to quit,” Reuters, 28 Sep. 2008, https://www.reuters.com/article/business/healthcare-pharmaceuticals/china-milk-victim-lawyers-say-pressed-to-quit-idUSTRE48R0ZK/.

[35] Celia Hatton, “Lawyer: I was tortured by Chinese police.” BBC, 12 Nov. 2015, https://www.bbc.com/news/av/world-asia-34794712.

[36] Qin Ma, “Depoliticization and Politicization: The Resilience of Chinese Sǐkē (Diehard) Lawyers’ Movement”, Harvard Human Rights Journal, 20 Apr. 2025, https://journals.law.harvard.edu/hrj/wp-content/uploads/sites/83/2025/05/03_HLH_38_1_Qin-Ma113-166.pdf.

[37] Pils, supra, note 31.

[38] Id.

[39] John Sudworth, “China's 'Super Vulgar Butcher' Wu Gan goes on trial,” BBC, 15 Aug. 2017, https://www.bbc.com/news/blogs-china-blog-40920495.

[40] Phillips, supra, note 9.

[41] Ma, supra, note 36.

[42] Id.

[43] Sudworth, supra, note 39.

[44] CHRD, “Sham Trial of Activist Wu Gan Targets Free Expression,” 14 Aug. 2017, https://www.nchrd.org/2017/08/sham-trial-of-activist-wu-gan-targets-free-expression/.

[45] Stanley Lubman, “After Crackdown on Rights Lawyers, China’s Legal Reform Path Uncertain,” Wall Street Journal, 30 Jul. 2015, https://www.wsj.com/articles/BL-CJB-27382.

[46] Louisa Lim, “China’s crackdown on Tiananmen memorials shows its obsession with security – and growing paranoia,” The Guardian, 4 Jun. 2024, https://www.theguardian.com/commentisfree/article/2024/jun/04/china-tiananmen-xi-jinping-national-security.

[47] Didi Tang, “Chinese media slam human rights lawyers as rabble-rousers,” Associated Press, 14 Jul. 2015, https://apnews.com/article/bed08b607ae1423189b762fab2c7f974.

[48] Id.

[49] John Sudworth, “Zhou Shifeng: Chinese law firm founder jailed for subversion,” BBC, 4 Aug. 2016, https://www.bbc.com/news/world-asia-china-36972206.

[50] deLisle, supra, note 8.

[51] Merriden Varrall, “China's legal reforms are far cry from Western-style justice,” Nikkei Asia, 18 May 2017, https://asia.nikkei.com/Politics/China-s-legal-reforms-are-far-cry-from-Western-style-justice.

[52] deLisle, supra, note 8.

[53] Id.

[54] Qin Ma, “How Chinese Lawyers Engage with the State,” Harvard Law School Center on the Legal Profession, Apr. 2025, https://clp.law.harvard.edu/knowledge-hub/magazine/issues/lawyers-between-democracy-and-authoritarianism/how-chinese-lawyers-engage-with-the-state/.

[55] deLisle, supra, note 8.

[56] Benjamin Parkin, “Where are China’s human rights lawyers?” Al Jazeera, 29 Feb. 2016, https://www.aljazeera.com/features/2016/2/29/where-are-chinas-human-rights-lawyers.

[57] Id.

[58] Safeguard Defenders, “Access Denied: China’s Vanishing Suspects,” 17 Nov. 2020, https://safeguarddefenders.com/sites/default/files/pdf/ACCESS_DENIED_%231_SGL_EN.pdf.

[59] Id.; Safeguard Defenders, “Access Denied: China’s False Freedom,” 25 Jan. 2021, https://safeguarddefenders.com/sites/default/files/pdf/ACCESS%20DENIED%20%232%20ENGLISH%20FINAL%20VERSION%20FULL_0.pdf.

[60] “Congressional-Executive Commission on China – Annual Report,” One Hundred Fifteenth Congress First Session, 5 Oct. 2017, https://www.congress.gov/115/cprt/JPRT26811/CPRT-115JPRT26811.pdf.

[61] Safeguard Defenders, “Access Denied: China’s Legal Blockade,” 6 Dec. 2021, https://safeguarddefenders.com/sites/default/files/pdf/ACCESS%20DENIED%203%20EN.pdf.

[62] Safeguard Defenders, supra, note 58.

[63] Emma Graham-Harrison, “China stepping up use of secret detention without trial, report warns,” The Guardian, 22 Jun. 2021, https://www.theguardian.com/world/2021/jun/22/china-stepping-up-use-secret-detention-without-trial-report-warns.

[64] Safeguard Defenders, supra, note 58.

[65] BBC, “Wang Quanzhang: China jails leading human rights lawyer,” 28 Jan. 2019, https://www.bbc.com/news/world-asia-china-47024825.

[66] Commission on China, supra, note 60.

[67] Id.

[68] Hong Kong Free Press (HKFP), “Jailed Chinese lawyer suffered ‘very cruel and sick torture’, force-fed medication, says wife,” 24 May 2017, https://hongkongfp.com/2017/05/24/jailed-chinese-lawyer-suffered-cruel-sick-torture-force-fed-medication-says-wife/.

[69] Commission on China, supra, note 60.

[70] Asian Lawyers Network (ALN), “Joint statement: Concern over the sentencing of prominent human rights lawyer Lu Siwei,” 6 May 2025, https://www.asianlawyers.net/statements/2025-05-06-lu-siwei-joint-statement; ALN, "Joint statement on lawyer Xu Zhiyong’s hunger strike over inhumane treatment in Lunan prison, China", 21 Nov. 2024, https://www.asianlawyers.net/statements/2024-11-21-xu-zhiyong-joint-statement.

[71] Emma Graham-Harrison, “China stepping up use of secret detention without trial, report warns,” The Guardian, 22 Jun. 2021, https://www.theguardian.com/world/2021/jun/22/china-stepping-up-use-secret-detention-without-trial-report-warns.

[72] Id.

[73] Safeguard Defenders, supra, note 58.

[74] Safeguard Defenders, supra, note 59.

[75] Id.

[76] China Change, supra, note 21.

[77] Safeguard Defenders, supra, note 59.

[78] Id.

[79] HRIC, supra, note 2.

[80] Parkin, supra, note 56.

[81] Safeguard Defenders, supra, note 61.

[82] Id.

[83] Human Right Watch, “China: Free Rights Lawyers, Reinstate Law Licenses,” 5 Jul. 2018, https://www.hrw.org/news/2018/07/06/china-free-rights-lawyers-reinstate-law-licenses.

[84] Id.

[85] Margaret Satterthwaite, “Letter to the Government of the People’s Republic of China,” Mandate of the Special Rapporteur on the independence of judges and lawyers, 14 Feb. 2024, https://spcommreports.ohchr.org/TMResultsBase/DownLoadPublicCommunicationFile?gId=28726.

[86] Id.

[87] Chris Buckley, “China Holds Secret Trial for Rights Lawyer After 3 Years in Detention,” The New York Times, 26 Dec. 2018, https://www.nytimes.com/2018/12/26/world/asia/china-wang-quanzhang-lawyer-trial.html; Benjamin Haas, “China convicts rights lawyer Li Heping of 'subversion of state power,’” The Guardian, 28 Apr. 2017, https://www.theguardian.com/world/2017/apr/28/china-convicts-rights-lawyer-li-heping-of-subversion-of-state-power.

[88] Id.

[89] Sarah Cook, “How Beijing’s Crackdown on Lawyers Affects Media Freedom,” Freedom House, 10 Aug. 2015, https://freedomhouse.org/article/how-beijings-crackdown-lawyers-affects-media-freedom.

[90] CHRD “Collective Punishment of Human Rights Defenders’ Families in China: The Annual Report on the Situation of Human Rights Defenders,” 15 Apr. 2024, https://www.nchrd.org/wp-content/uploads/2024/04/If-I-Disobey-My-Family-will-Suffer.pdf.

[91] Council of Bars and Law Societies of Europe (CCBE), “Situation of lawyers in China,” 31 Oct. 2016, https://www.ccbe.eu/fileadmin/speciality_distribution/public/documents/HUMAN_RIGHTS_LETTERS/_REPORTS_-_RAPPORTS/2016/EN_HRL_20161031_CCBE_Report_situation_lawyers_China.pdf.

[92] China Change, supra, note 21.

[93] PEN America, “ ‘709 Crackdown 2.0’ Global call against China’s renewed crackdown on human rights lawyers,” 10 Jul. 2023, https://pen.org/global-call-against-chinas-renewed-crackdown-on-human-rights-lawyers/.

[94] Emily Chan, “Six Years After Crackdown, China's Rights Lawyers 'Struggling to Exist',” Radio Free Asia, 8 Jul. 2021, https://www.rfa.org/english/news/china/lawyers-07082021101655.html.

[95] PEN America, supra, note 93.

[96] Human Rights Council Fifty-seventh session (HRC57), “Annual report of the United Nations High Commissioner for Human Rights and reports of the Office of the High Commissioner and the Secretary-General. Report of the Secretary-General,” 9 Sep. 2024, https://docs.un.org/en/A/HRC/57/60.

[97] Id.

[98] Asahi Shimbun, “Chinese human rights lawyer chased out of 13 homes in 2 months,” 23 Jun. 2023, https://www.asahi.com/ajw/articles/14940058.

[99] Id.

[100] Id.

[101] HRC57, supra, note 96.

[102] Id.

[103] Wang Qiaoling, “Eight Years as a Mother (2),” China Change, 6 Oct. 2023, https://chinachange.org/2023/10/06/eight-years-as-a-mother-2/.

[104] Asahi Shimbun, supra, note 98.

[105] Id.

[106] Satterthwaite, supra, note 85.

[107] “Measures on the Administration of Law Firms,” Translated by China Law Translate, 18 Dec. 2018, https://www.chinalawtranslate.com/en/measures-on-the-administration-of-law-firms-%EF%BC%882018%EF%BC%89/.

[108] “Measures on the Administration of Lawyers' Practice,” Translated by China Law Translate, 27 Oct. 2016, https://www.chinalawtranslate.com/en/measures-on-the-administration-of-lawyers-practice/.

[109] US Congressional Executive Commission on China, “Five Years after 709 Crackdown, Lawyers Continue to Face Repression and Punishment”, 9 Jul. 2020, https://www.cecc.gov/publications/commission-analysis/five-years-after-709-crackdown-lawyers-continue-to-face-repression.

[110] Id.

[111] Chan, supra, note 94.

[112] “Measures on the Administration of Law Firms,” supra, note 107.

[113] Id.

[114] Id.

[115] Id.

[116] Id.

[117] “Measures on the Administration of Lawyers' Practice,” supra, note 108.

[118] Id.

[119] Id.

[120] Id.

[121] Id.

[122] The Law Society of England and Wales (LSEW), “Stakeholder Submission to the UN Human Rights Council’s Universal Periodic Review – CHINA,” 29 Jan. 2024, https://uprdoc.ohchr.org/uprweb/downloadfile.aspx?filename=12472&file=CoverPage.

[123] CHRD, “Joint Analysis of the Measures on the Administration of Law Firms and Administrative Measures for the Practice of Law by Lawyers of the People’s Republic of China,” 22 Mar. 2019, https://www.nchrd.org/2019/05/joint-analysis-of-admin-measures-for-lawyers-and-law-firms/.

[124] Lawyers for Lawyers, “Mid-term Report – Review of the implementation of recommendations with respect to the rule of law and the role of human rights defenders accepted by China during the UPR in 2018,” 12 Aug. 2021, https://lawyersforlawyers.org/wp-content/uploads/2021/08/Final-mid-term-review-China-L4L-LRWC-final.pdf.

[125] Id.

[126] CCBE, supra, note 91.

[127] LSEW, supra, note 122.

[128] Human Rights Watch, supra, note 83. 

[129] CHRD, supra, note 123.

[130] Human Rights Watch, “China: Justice Ministry Pressures Law Firms,” 19 Sep. 2017, https://www.hrw.org/news/2017/09/19/china-justice-ministry-pressures-law-firms.

[131] Id.

[132] Satterthwaite, supra, note 85.

[133] LSEW, supra, note 122.

[134] Id.

[135] Id.

[136] Id.

[137] Lawyers for Lawyers, supra, note 124.

[138] Palmer, supra, note 16.

[139] Parkin, supra, note 56.

[140] Amy Hawkins, “Rights groups call on Laos to release lawyer held after fleeing China,” The Guardian, 3 Aug. 2023, https://www.theguardian.com/world/2023/aug/03/rights-groups-laos-release-lawyer-china-lu-siwei.

[141] Radio Free Asia, “China Moves to Shutter Law Firm at Center of Crackdown on Rights Lawyers,” 6 Mar. 2016, https://www.rfa.org/english/news/china/firm-03062018144558.html.

[142] Chris Buckley, “Trial Looms After Seaside Gathering of Chinese Activists,” The New York Times, 8 Jan. 2022, https://www.nytimes.com/2022/01/08/world/asia/china-rights-defense-activists.html.

[143] Lawyers for Lawyers, “The 709-Crackdown, the alarming state of lawyers’ rights in China and Hong Kong, and a new wave of repression,” 9 Jul. 2023, https://www.lawyersforlawyers.org/the-709-crackdown-the-alarming-state-of-lawyers-rights-in-china-and-hong-kong-and-a-new-wave-of-repression/.

[144] Frontline Defenders, “Woman human rights defender Li Yuhan returned home after completing sentence,” https://www.frontlinedefenders.org/en/case/woman-human-rights-defender-and-lawyer-li-yuhans-health-deteriorates-under-prolonged-detention.

[145] Lawyers for Lawyers, “Joint statement on the suspension of Lin Qilei’s and revocation of Liang Xiaojun’s legal practice licenses,” 7 Dec. 2021, https://www.lawyersforlawyers.org/joint-statement-on-the-suspension-of-lin-qileis-and-revocation-of-liang-xiaojuns-legal-practice-licenses/.

[146] Ma, supra, note 36.

[147] Id.

[148] Id.

[149] Id.

[150] Id.

[151] Id.