In this case before a Chamber of the International Court of Justice, El Salvador and Honduras, by a Special Agreement dated May 24, 1986, requested that the Chamber delimit the land frontier and determine the legal status of certain islands and waters in the general area of the Gulf of Fonseca. The gulf, located on the Pacific coast of Central America, is bordered by El Salvador, Honduras and Nicaragua. Nicaragua filed an application for permission to intervene in the case on November 17, 1989, pursuant to Article 62 of the Statute of the Court, which permits a state to request intervention if the state considers “that it has an interest of a legal nature which may be affected by the decision in the case.”

In the case of the Mexican Union Railway, Ltd., decided in February, 1930, the British-Mexican Claims Commission, set up in accordance with the Convention of November 19,1926, added another stone to the somewhat unsteady structure of decisions on the Calvo Clause. The majority of the Commissioners enthusiastically adopted the considerationsof the United States-Mexican General Claims Commission in the North American Dredging Case, “ not thinking it necessary to repeat them, or possible to express them better.” Even the British Commissioner, Sir John Percival, who dissented, differed from the majority mainly in regard to the application of the opinion in the North American Dredging Case to the case at bar, and was not less cordial in his approval of that opinion.

On February 28, 2013, the appeals chamber (Chamber) of the International Criminal Tribunal for the Former Yugoslavia (ICTY) overturned the 2011 conviction of General Momčilo Perišsicć, the former head of the Yugoslav Army (VJ), for aiding and abetting war crimes in Bosnia-Herzegovina and Croatia. By a 4-1 vote, the Chamber held that “specific direction” is an essential element of liability for the actus reus of aiding and abetting the crimes of murder, extermination, inhumane acts, attacks on civilians, and persecution as crimes against humanity and/or violations of the laws or customs of war. It also held that Perišsicć lacked the necessary “effective control” over his subordinates to subject him to command responsibility for their violations of the laws and customs of war.

On October 12, 2017, the United States announced its intent to withdraw from the United Nations Educational, Scientific and Cultural Organization (UNESCO), citing “concerns with mounting arrears …, the need for fundamental reform in the organization, and continuing anti-Israel bias.” The United States will remain a full UNESCO member until December 31, 2018, when the withdrawal becomes effective. Thereafter, it will continue to engage with UNESCO as a non-member observer state.