Only Natural Persons Subject To Suit.

The family of the deceased brought suit against The Palestinian Liberation Organization and The Palestinian Authority under the Torture Victim Protection Act of 1991 which authorizes a cause of action against an individual for acts of torture and extrajudicial killing committed under authority of color of law of any foreign nation.  In this case, Palestinian intelligence officers imprisoned, tortured and killed a naturalized U.S. citizen.  The U.S. Supreme Court affirmed dismissal of the action after concluding the word “individual” in the statute referred to a human being, not an organization, and that the act extended liability only to natural persons.  Mohamad v. Palestinian Authority  (U.S. Sup. Ct.; April 18, 2012) 132 S.Ct. 1702, [182 L.Ed.2d 720].