Prof. Young writes: "The argument for customary international law as it is
most often made is that it has the same status as federal common law, and
it is similar in form as well as it comes from the courts rather than the
legislature.  All of the general separation of powers, federalism, and
democratic concerns with federal common law are very similar for customary
international law.  Perhaps the authority for it can be rationalized in
terms of executive acquiescence, but as a practical matter, applied in
human rights litigation for example, it is law divined by courts."

COMMENT: I am a little puzzled by your statement that customary
international law as a practical matter is law divined by courts in, e.g.,
in human rights litigation.  Most of the international human rights
litigation (both in U.S. and international courts) of which I am aware uses
multilateral human rights treaties that were not established by domestic or
international courts.  These treaties were adopted/ratified by
representatives of the nation-state. In fact, I am having trouble thinking
of many cases that strictly used CUSTOMARY international human rights law
because there just wasn't much out there until treaties started to
articulate them.

Prof. Young continues:  "Moreover, the jurisprudence at the origins of
debates over federal common law -- the law merchant of Swift v Tyson --
_was_ customary international law.  So both as a matter of substance and of
pedagogy, I think the questions ought to be linked.  And whether or not you
agree on the merits, the question just _are_ linked in the literature
debating this issue."

COMMENT:  I agree with you as to the fact that federal common law has been
linked to customary international law in the literature.

Francisco Forrest Martin

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