The Inter-American Commission on Human Rights (IACHR) issued a landmark merits decision in 2025 holding the United States internationally responsible for the torture and death of Mexican national Anastasio Hernández Rojas, and for denying his family justice. The Commission found violations of the protections of life, humane treatment during arrest, health, and access to justice in the American Declaration of the Rights and Duties of Man (American Declaration) and ordered the United States to reopen the criminal investigation, impose sanctions, provide legal remedies and adopt non-repetition measures, including aligning use-of-force standards with international law, such as banning electric shock weapons, after specific legal findings of torture by the European Court of Human Rights and the UN Rapporteur, which both regarded its use as disproportionate, unnecessary, and inhumane.1

In Türkiye Halk Bankasi A.S. v. United States, the Supreme Court held that the Foreign Sovereign Immunities Act (FSIA) does not apply to criminal prosecutions of foreign state instrumentalities. The Court found that FSIA’s text and structure address only civil actions. On remand, the Second Circuit ruled that Halkbank lacked common-law immunity from criminal prosecution, deferring to the Executive Branch’s decision to prosecute and concluding that state-owned corporations enjoy no immunity for commercial activity under common law. The court’s analysis relied primarily on pre-1976 U.S. cases rather than international law. The Supreme Court denied certiorari in October 2025, ending the immunity dispute.