Lawsuits alleging violations of international human rights must satisfy the standard personal jurisdiction requirements for a federal civil lawsuit. Beyond this threshold issue, determining who can be sued triggers complicated liability issues, some of which are still hotly contested. The simplest human rights cases follow the Filártiga model: a lawsuit against the torturer, a former government official. 1 But many cases involve one or more variations on this model: non-state perpetrators, who may or may not act in coordination with state actors; commanding officers, or civilian leaders charged with responsibility for abuses committed by their subordinates; or defendants sued because they assisted the direct perpetrator in some way-a corporation that funds security forces who torture civilians, for example, or a military officer who helps select which prisoners will be killed.
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