On October 23, 2015, the U.S. Court of Appeals for the District of Columbia (Court) upheld a lower court’s dismissal of a suit brought by a U.S. citizen against the FBI for alleged torture incidents in Africa. Mr. Meshal had sued under the Bivens doctrine, which allows a private action for damages against the federal officers alleged to have violated the citizen’s constitutional rights. His complaint alleged that he had been arrested and detained in secret, without access to counsel, moved around several African countries, and had been threatened with torture and death. The Court found that a Bivens claim was not available in this case, both because of the extraterritoriality of the FBI’s conduct and out of considerations regarding the separation of powers. The Court stated “[t]he Judiciary is generally not suited to ‘secondguess’ executive officials operating in ‘foreign justice systems’” and “recognize[ed] that tort remedies in cases involving matters of national security and foreign policy are generally left to the political branches.”