85,000 is the mininum, not the maximum. From the article...

"At best, the numbers released by the Human Rights Ministry and those obtained by the AP are a minimum of the number who died. Emmanuel d'Harcourt from the New York-based International Rescue Committee, who's participated in mortality surveys in such places as Sudan and Sierra Leone, said the figures are undoubtedly low and that considering the challenges associated with counting those killed in the Iraq conflict, a true figure might never be reached."