A congressional inquiry to the Department of State concerned the practice of signing documents such as the Trilateral Statement concluded at Moscow on January 14, 1994, by President William J. Clinton, Russian Federation President Boris Yeltsin, and Ukraine President Leonid M. Kravchuk and the status of such documents under both United States and international law and practice.

In August 2012, the First Criminal Division of the Court of Cassation (Supreme Court or Court), the highest Italian domestic court, issued a judgment upholding Germany’s sovereign immunity from civil claims brought by Italian war crime victims against Paul Albers and eight others in the Italian courts (Albers). In so doing, the Court overruled its own earlier decisions and also reversed the judgment of April 20, 2011, by the Italian Military Court of Appeal (Military Court), which had upheld such claims relating to war crimes committed by German forces in Italy during World War II. With this ruling, the Court of Cassation put an end to its decade long effort to find an exception to the well-known rule of customary international law providing for sovereign immunity from foreign civil jurisdiction for acts jure imperii. This revirement resulted from the Court’s decision to give effect to the judgment of the International Court of Justice (ICJ) in Germany v. Italy.

This note is meant to take the place of a review of the first six volumes of the Reports of the Decisions of the Court of Justice of the European Communities which are published in the four official languages of the European economic communities and contain the decisions rendered during the years 1954–1960.