The following excerpt is from Morales v. Brown, Case No. 1:14-cv-01717-LJO-SAB (E.D. Cal. 2015):
To be actionable under the ATS as a crime against humanity requires "especially wicked conduct that is carried out in an extensive, organized, and deliberate way, and that is plainly unjustified. It is this kind of hateful conduct that might make someone a common enemy of all mankind." Mamani v. Berzain, 654 F.3d 1148, 1156 (11th Cir. 2011).
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