The following excerpt is from Nahl v. Jaoude, 968 F.3d 173 (2nd Cir. 2020):
10 See Sosa v. Alvarez-Machain , 542 U.S. 692, 762, 124 S.Ct. 2739, 159 L.Ed.2d 718 (2004) (Breyer, J., concurring) ("Today international law will sometimes ... reflect not only substantive agreement as to certain universally condemned behavior but also procedural agreement that universal jurisdiction exists to prosecute a subset of that behavior. ... That subset includes torture, genocide, crimes against humanity, and war crimes." (emphasis added)).
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