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Yesterday, the Supreme Court issued a unanimous decision in Mohamad v. Palestinian Authority, No. 11-88, holding that companies and other organizations cannot be sued under the U.S. Torture Victim Protection Act ("TVPA"). That statute creates a federal private right of action for torture and extrajudicial killing committed by "[a]n individual" acting under color of foreign law. 28 U.S.C. § 1350 & note. In short, the Court held that "individual" means a natural person, not a legal entity or organization. The case marks an important limitation on liability of corporations and others for acts committed outside the United States. 

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