In the case of Asid Mohamad, Individually and for the Estate of Azzam Rahim, Deceased, et al., Petitioners v. Palestinian Authority et al., 2011, the U.S Supreme Court ruled that non-human entities such as organizations or corporations cannot be held liable under a federal law allowing foreign torture victims to seek damages in U.S courts. The petitioners were relatives of a naturalized US citizen who was allegedly tortured and killed by Palestinian intelligence officers. They sought civil damages from the Palestinian Authority and Palestine Liberation Organization under the Torture Victim Protection Act (TVPA). However, interpreting "individual" within TVPA's text as referring only to natural persons rather than organizational entities like those being sued here, Justice Sonia Sotomayor delivered an unanimous opinion rejecting this interpretation on behalf of all nine justices.

The dissenting opinion in the case of Mohamad v. Palestinian Authority argued that the Torture Victim Protection Act (TVPA) should apply to organizations, not just individuals. The majority ruling held that "individual" as used in TVPA refers only to natural persons and therefore does not impose liability on organizations such as the Palestinian Authority. However, Justice Sonia Sotomayor disagreed with this interpretation, arguing it was inconsistent with Congress's intent when passing TVPA and could potentially limit victims' ability to seek redress for human rights abuses committed by non-state actors or entities like terrorist groups or corporations. She also pointed out that other federal laws have been interpreted to include both natural persons and legal entities under their definition of 'individual'. Therefore, she believed there is no reason why 'individual' in TVPA cannot be read similarly.