Historical Dictionary of Terrorism Third Edition

ALIENATION • 15imprisoned, assaulted, and raped; for the plaintiffs’ emotional distress;and for having caused the “disappearance” of the mother of one of theplaintiffs. The Northern U.S. District Court of California ruled that theplaintiffs could sue only for the causes of torture, arbitrary detention,and summary execution, as these were the only causes recognized underthe “law of nations” at the time of enactment of the Statute. In thecase of Ortiz v. Gramajo (1995), the federal district judge Douglas P.Woodlock ruled that a former Guatemalan general, Hector Gramajo,was obliged to pay a nun, Sister Ortiz, of the Ursuline Order, $7.5 millionfor damages due to her being kidnapped, raped, and tortured duringinterrogation by Guatemalan soldiers under Gramajo’s commandwho had accused her of collaboration with leftist insurgents.These cases are unusual since it is unlikely that the authors of theStatute contemplated that foreign nationals would seek redress ofgrievances in U.S. courts for human rights abuses committed outsidethe United States. On the other hand, human rights advocates viewthis as an important avenue for U.S. citizens to seek redress of grievancesfor damages caused by state repression abroad or for damagescaused by state-sponsored terrorist groups. Therefore, in Doe v. RafaelSaravia (2004), the U.S. District Court for the Eastern Districtof California found ARENA head of security Álvaro Rafael Saravialiable for damages to the family of Salvadoran Archbishop ÓscarRomero under the Statute. The most recent U.S. Supreme Court rulingon the statute was Sosa v. Alvarez-Machain (2004), upholding theprior Supreme Court decision in United States v. Alvarez-Machain(1992), which did not allow foreigners illegally abducted by U.S.agents from foreign jurisdictions into the United States for trial hereto use the Alien Tort Claims Act to sue the U.S. government for kidnapping.This finding strengthens the ability of the U.S. governmentto engage in forms of rendition other than formal extradition. On18 April 2007 Chinese dissidents Wang Xiaoning and Yu Ling begana lawsuit against the Internet service provider Yahoo Inc. in theU.S. District Court for Northern California, invoking the Alien TortClaims Act to recover damages from Yahoo for having provided theChinese government with information used to prosecute them.ALIENATION. Among the possible psychological causes for peoplebeing attracted to political violence or terrorism is the phenomenonof alienation, meaning that the people or group view the nation-state