The Torture Victim Protection Act (“TVPA”) was passed by the U.S. Congress in 1992 “to carry out obligations of the United States under the United Nations Charter and other international agreements pertaining to the protection of human rights establishing a civil action for recovery of damages from an individual who engages in torture or extrajudicial killing.” Pub.L. No. 102-256, 106 Stat. 73 (1992) (codified 28 U.S.C. § 1350). The Ninth Circuit recently held that the TVPA does not apply to corporations, but only to individuals who commit torture or extrajudicial killing, and therefore, there is no liability under the TVPA against corporations.
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