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20 Penn St. Int'l L. Rev. 253 (2001-2002)
Justice for Comfort Women: Will the Alien Tort Claims Act Bring Them the Remedies They Seek

handle is hein.journals/psilr20 and id is 261 raw text is: Comments
Justice for Comfort Women: Will the
Alien Tort Claims Act Bring Them the
Remedies They Seek?
I.   Introduction
The International Law Commission recognizes five crimes
under international law:   aggression, genocide, crimes against
humanity, crimes against United Nation personnel, and war crimes.I
Although these crimes are internationally recognized, it is often
difficult for individual victims to get any redress.2 One option that
the United States offers for victims of international law violations is
the Alien Tort Claims Act (ATCA).3 It grants foreigners the
opportunity to sue in a United States District Court for tortious
conduct that violates international law or a treaty with the United
States.4 In recent years, the two-hundred-year-old statute has been
1. Beth  Stephans, Conceptualizing  Violence: Present and  Future
Developments in International Law. Panel I: Human Rights and Civil Wrongs at
Home and Abroad: Old Problems and New Paradigms: Conceptualizing Violence
Under International Law: Do Tort Remedies Fit the Crime? 60 ALB. L. REV. 579,
581 (1997).
2. Id.
3. 28 U.S.C. § 1350 which provides: original jurisdiction of any civil action
by an alien for a tort only, committed in violation of the law of nations or a treaty
of the United States.
4. Id.

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