Noah was awarded a Bernstein Fellowship for 1998-99 to conduct constitutional development work in the Horn of Africa. When war broke out in May 1998 between Eritrea and Ethiopia, Noah turned his attention to investigating and documenting war-related human rights abuses, visiting refugee camps on both sides of the border, writing articles for publication in U.S. media, and sharing his findings with human rights groups, aid agencies, and UN officials. In particular, Noah sought to highlight the gross violation of rights resulting from Ethiopia�s expulsion of thousands of ethnic Eritreans and the expropriation of their property.