The Torture Memos and Accountability
Introduction

Introduction
On May 30, 2008, delegates at the Dublin Diplomatic Conference on Cluster Munitions adopted the Convention on Cluster Munitions (CCM), a new treaty that seeks to ban the use, development, acquisition, stockpiling, retention, and transfer of cluster munitions.[1] The CCM will be opened for signature on December 3, 2008 (CCM, Article 15).
1. Introduction
I. INTRODUCTION
On July 14, 2008, the Prosecutor of the International Criminal Court ("ICC", "Court") applied to Pre-Trial Chamber III of the Court for an arrest warrant against the President of Sudan, Omar Hassan Ahmad al-Bashir.[1] This is the first time that the Prosecutor filed charges against a sitting head of state.
Introduction
On June 12, 2008, the Supreme Court ruled against the U.S. government in cases brought by foreign nationals challenging their detention at the Guantanamo Bay, Cuba military facility.[1] A five-justice majority in Boumediene v. Bush held that the Military Commissions Act of 2006 (MCA)[2] violated the U.S.
I. Introduction
On February 28, 2008, the Grand Chamber of the European Court of Human Rights (ECtHR) handed down its judgment in Saadi v Italy.[1] In this case, Italy and the United Kingdom (as third party intervener) claimed that the climate of international terrorism called into question the appropriateness of the ECtHR's existing jurisprudence on states' non-refoulement obligation under Article 3 of the European Convention on Human Rights (European Conve