2003-2004 Survey of International Law in the Second: Foreign Sovereign Immunities Act

In Abrams v. Societe Nationale des Chemis de Fer Francais, 332 F .3d 173 (2002), plaintiff brought suit this individually and on behalf of other Holocaust victims and such heirs against the French International Railroad, Societe Nationale des Chemis de Fer Francais [hereinafter SNCF] for actions arising out of the operation of trains which transferred thousands of French civilians to Nazi concentration camps. The allegation stated that SNCF violated customary international law by committing crimes against humanity and acts of war crimes.