United States v. Belfast (Chuckie Taylor)
United States Court of Appeals for the Eleventh Circuit
611 F.3d 783 (2010)
- Written by Haley Gintis, JD
Facts
Roy M. Belfast, Jr. (Emmanuel) (defendant) was born in the United States and subsequently moved to Liberia. Between 1999 and 2003, Emmanuel created and oversaw Liberia’s Anti-Terrorism Unit (ATU). Emmanuel was appointed to the position by his father, Charles Taylor, who served as Liberia’s president. Emmanuel established Gbatala Base to train the men he had recruited to serve in the ATU. Emmanuel committed cruel and inhumane acts of violence and torture on the base. In response, the United States (plaintiff) charged Emmanuel with violating numerous laws, including the Torture Act. Emmanuel was convicted and appealed on the ground that the Torture Act was unconstitutional because it allowed the federal courts of the United States to assume jurisdiction over an extraterritorial act of torture solely because the torturer was served while present in the United States. Emmanuel further argued that the Torture Act was unconstitutional because Congress’s sole authority to pass the act was derived from the Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (the CAT), and the act’s broad jurisdiction over extraterritorial actions exceeded the CAT. The United States Court of Appeals for the Eleventh Circuit considered the case.
Rule of Law
Issue
Holding and Reasoning (Marcus, J.)
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