The Torture Victim Protection Act (TVPA), 28 U.S.C. § 1350 note, was enacted in 1991 to provide a private right of action in U.S. courts for victims of torture or extrajudicial killing carried out under authority or color of law of a foreign nation. Unlike the Alien Tort Statute, the TVPA was expressly enacted by Congress. The Supreme Court held in Mohamad v. Palestinian Authority (2012) that the TVPA applies only to natural persons, not organizations. The 2026 Cisco Systems v. Doe I case asks whether the TVPA allows aiding-and-abetting claims — meaning whether someone who helped another person commit torture can be sued, not just the direct torturer.