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Over the last twenty-five years some aliens present
within the United States have initiated action
against other aliens for crimes transgressing the law
of nations committed abroad. This trajectory is
considered by some as progress in international law,
since only a few decades earlier this body of law
concerned itself exclusively with the relations among
independent states. Therefore the ability to employ
international instruments for the advancement of
individual human rights is perhaps a cause celebre.
But this growing practice has also generated a
significant controversy and opposition....