Justice for Ms Dhu: Accounting for Indigenous Deaths in Custody in Australia

Ms Dhu, an Aboriginal woman belonging to the Yamatji nation, died in police custody in South Hedland, Western Australia, in 2014 within 48 hours of being incarcerated for failing to pay fines. The coroner’s report found that both the police force and medical institution failed to discharge the duty of care owed to Ms Dhu, as their behaviour fell below what was expected of someone in their position. However, the coronial inquiry was unable to account for the ways in which state power and possessive sovereignty is invested in the deaths of Indigenous peoples. This article connects Ms Dhu’s life and death to forms of gendered, institutional and structural racism endemic to the Australian settler state. We then turn to examine the possibilities of justice for Ms Dhu through aesthetic attempts to memorialize her in public spaces of the city of Perth, which carry a promise of justice through their ability to challenge the settler-colonial logic that made possible Ms Dhu’s invisible suffering and the lack of accountability for her death