Each of these three defenses such as Sovereign Immunity, Extraterritoriality and Political Question Doctrine could be expected to be raised in any attempt to sue the United States over the Jeju massacre, and each of them could be expected to be the basis for an order of the court dismissing the suit. Moreover, if the court regarded the suit as frivolous, the plaintiff and its attorneys could be subject to sanctions under Rule 11 of the Federal Rules of Civil Procedure.

Abstract
Introduction
Statement of Facts
Human Rights and Reparative Justice
Discussion
Exhaustion
Sovereign Immunity
Extraterritoriality
Political Question Doctrine

• Lennox S. Hinds(Rutgers University School of law)