to enforce international human rights law in the U.S. CJA's litigation draws on two principal statutes: the Alien Tort Statute (ATS) (also known as the Alien Tort Claims Act) and the Torture Victim Protection Act (TVPA). These statutes grant U.S. courts jurisdiction to hear civil actions filed against perpetrators of gross human rights violations, even when those violations took place overseas. Since the U.S. 2nd Circuit Court of Appeal's landmark 1980 decision in Filartiga v. Pena-Irala, this class of civil action has opened up U.S. federal courts to the implementation of international law and human rights safeguards: In the twentieth century the international community has come to recognize the common danger posed by the flagrant disregard of basic human rights ... Among the rights universally proclaimed by all nations ... is the right to be free of physical torture. Indeed, for purposes of civil liability, the torturer has become—like the pirate and slave trader before him—hostis humani generis, an enemy of all mankind. Our holding today ... is a small but important step in the fulfillment of the ageless dream to free all people from brutal violence. The authors of International Human Rights Litigation in U.S. Courts—the authoritative manual for ATS and TVPA litigation—echo the Filartiga ruling: Although not a substitute for other means of holding perpetrators accountable, human rights litigation contributes to an important long-term objective: working toward a world in which those who commit gross violations of human rights are brought to justice swiftly, in whatever country they try to hide. Legal scholar Beth Van Schaack has argued that these broader objectives place human rights litigation in line with the public impact litigation model pioneered by the American civil rights movement. Both strategies aim to effect systemic social change through the legal process. In the majority of CJA's cases, however, the primary focus remains on direct client advocacy: the needs of a client take first priority, while a case's broader impact remains a second order effect. (cf. "With All Deliberate Speed: Civil Human Rights Litigation as Tool for Social Change") Universal jurisdiction Underpinning CJA's mission is the principle of universal jurisdiction. With roots in the ancient body of law related to piracy and slave-traders, this doctrine of international law holds that certain crimes are so egregious that the perpetrators may be held accountable wherever they are found. Since the Nuremberg Trials of 1945-49, modern jurisprudence has extended the