On January 30, 2014, the Fourth Chamber of the Court of Justice of the European Union (the Court) issued its judgment [3] in Diakité v. Commissaire Général aux Réfugiés et aux Apatrides, ruling on the issue of the interpretation of “internal armed conflict” as used in Directive 2004/83. Directive 2004/83 [4] provides “subsidiary protection” for people who do not qualify as refugees if upon being returned to their home county they would “face a real risk of suffering serious harm,” defined to include “serious and individual threat to a civilian’s life or person by reason of indiscriminate violence in situations of international or internal armed conflict.” According to the press release [5], the Court found that the concept of internal armed conflict as used in Directive 2004/83 “is unique to that directive and is not directly reflected in international humanitarian law.” Thus, giving it an “autonomous interpretation,” the Court held that an internal armed conflict, for the purposes of Directive 2004/83, exists if “a State’s armed forces confront one or more armed groups or . . . [if] two or more armed groups confront each other.”