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Record W256412339

International Law - Prohibition on Refoulement - Remedies - Maher Arar V. John Ashcroft

2009· article· en· W256412339 on OpenAlexaboutno aff
Daniel P Ryan

Bibliographic record

VenueSuffolk transnational law review · 2009
Typearticle
Languageen
FieldSocial Sciences
TopicInternational Law and Human Rights
Canadian institutionsnot available
Fundersnot available
KeywordsLawPlaintiffTortureState (computer science)DamagesGovernment (linguistics)SociologyPolitical scienceHuman rightsPhilosophy
DOInot available

Abstract

fetched live from OpenAlex

The prohibition on refoulement is a fundamental human right enshrined in both customary international and law. (1) In Arar v. Ashcroft, (2) Court of Appeals for Second Circuit considered plaintiff Maher Arar's claim for, inter alia, damages under Torture Victims Prevention Act (T.V.P.A.) arising from his extraordinary rendition to Syria. (3) Arar alleged that defendants, U.S. government officials, rendered him to Syria with knowledge or intention that he would be tortured and interrogated by Syrian authorities. (4) The Second Circuit held that Arar failed to state a claim under T.V.P.A. and dismissed case. (5) On September 26, 2002, authorities at John F. Kennedy airport in New York detained Arar, a dual citizen of Syria and Canada, while he was in transit from Tunisia to Canada. (6) Arar was told that he was inadmissible to United because U.S. government had determined he was a member of al Qaeda. (7) Pursuant to this determination, Director of Regional Office of I.N.S.J. Scott Blackman, authorized Arar's removal from United without further process. (8) Although Arar designated Canada as country to which he wished to be sent, U.S. officials instead allegedly flew him to Jordan where he was handed over to Syrian officials, driven to Syria and placed in detention. (9) In Syria, Arar was allegedly held in an underground cell six feet long and three feet wide for approximately twelve months. (10) During his detention, Arar claimed that he was subjected to and psychological including regular beatings and threats of severe physical harm. (11) Arar further alleged that defendants provided Syrian authorities with information about him, suggested subjects for interrogation, and received all information coerced from [Arar] during interrogations. (12) Following his release from Syrian detention, Arar filed a civil action in 2004 against numerous individuals, including: former U.S. Attorney General John Ashcroft; Federal Bureau of Investigations (F.B.I.) Director Robert Mueller; Secretary of Homeland Security Tom Ridge; former Immigration and Naturalization Service (I.N.S.) Commissioner James W. Ziglar; Regional Director of Regional Office of I.N.S. J. Scott Blackman; and several other named and unnamed employees of F.B.I. and I.N.S. (13) Arar alleged, inter alia, that defendants acted in concert with Jordanian and Syrian officials, and under color of Syrian law, to conspire and/or aid and abet in violating his right to be free from torture in violation of T.V.P.A. (14) Arar requested compensatory and punitive damages under T.V.P.A. for violations of his international human rights. (15) The District Court dismissed Arar's complaint in August 2006. (16) On appeal, Second Circuit Court of Appeals upheld District Court dismissal of Arar's claims. (17) The Alien Tort Statute (A.T.S.) grants federal district courts original jurisdiction over any civil action by an alien for a tort committed in violation of law of or a of United States. (18) Torts in violation of of nations include, inter alia, torture, extrajudicial killing, war crimes, disappearance, and arbitrary detention. (19) To gain jurisdiction under A.T.S., plaintiff must show that is either self-executing and provides for a private right of action or, if is non-selfexecuting, that it has been implemented through domestic legislation. (20) Where a tort violates both the of prong of A.T.S. and treaty of United States prong of statute, plaintiffs are not barred from raising claims under either prong of A.T.S. (21) Under customary law, principle of non-refoulement prohibits from rejecting, returning, removing, or expelling an individual to a country where there is a substantial risk of facing torture, cruel, inhuman or degrading treatment, or persecution. …

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

How this classification was reachedexpand

Full frame distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.001
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesInsufficient payload (model declined to judge)
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Theoretical or conceptual · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.959
Threshold uncertainty score0.996

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0010.000
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0010.000
Scholarly communication0.0000.001
Open science0.0000.000
Research integrity0.0000.000
Insufficient payload (model declined to judge)0.0050.000

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.029
GPT teacher head0.334
Teacher spread0.305 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one teacher head, not a consensus.

Study designTheoretical or conceptual
Domainnot available
GenreEmpirical

How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".

Quick stats

Citations0
Published2009
Admission routes1
Has abstractyes

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