On Oct. 21, the federal District Court for the Eastern District of Virginia affirmed, in the well-known Blackwater/Xe case, that the murder of civilians in connection with an armed conflict overseas is actionable in a US Court under the controversial Alien Tort Claims Act of 1789. The court relied on the universal acceptance, everywhere in the world, of Common Article 3 to the Geneva Conventions, which prohibits the murder of civilians in an armed conflict.