In United States v. Duarte-Acero, the Eleventh Circuit Court of Appeals held that the International Covenant on Civil and Political Rights does not regulate the extraterritorial conduct of U.S. government agents. Additionally, the court held that the Covenant is not self-executing and therefore that it does not create individual rights that are judicially enforceable in U.S. courts.

Podkolzinav. Latvia. App. No. 46726/99. At <http://www.echr.coe.int/Eng/Judgments.htm>. European Court of Human Rights, April 9, 2002.

In Podkolzina v. Latvia, the European Court of Human Rights held that Latvia violated the applicant's right to stand as a candidate for parliamentary elections, as set out in Article 3 of Protocol No. I to the European Convention on Human Rights in striking the applicant off the list of registered candidates due to allegedly inadequate language skills. The Court ordered Latvia to pay 9,000 for nonpecuniary damages and for costs and expenses.

The applicant, a member of the Russian-speaking minority in Latvia, acquired an official language certificate in January 1997. The certificate was issued by a regional board of the State Language Centre, composed of five examiners. On the basis of written and oral examinations that were evaluated in accordance with criteria and levels of competence defined by legal regulations, the five-member board certified that Podkolzina's command of the Latvian language corresponded to the “third level.”

Republic of South Africa v. Grootboom. Case No. CCT 11/00. 2000 (11) BCLR 1169. Constitutional Court of South Africa, October 4, 2000.

Minister of Health v. Treatment Action Campaign. Case No. CCT 8/02. At <http://www.concourt.gov.za>.

Constitutional Court of South Africa, July 5, 2002.

Two cases decided by the Constitutional Court of South Africa in 2000 and 2002 implement several economic, social, and cultural rights guaranteed by the Constitution of South Africa. The decisions illuminate the role in such reasoning of human rights treaties to which South Africa is a state party or a signatory. They also analyze General Comment No. 3 of die UN Committee on Economic, Social and Cultural Rights (Committee). These cases, Republic of South Africa v. Grootboom, decided October 4,2000, and Minister of Health v. Treatment Action Campaign, decided July 5, 2002, illuminate questions concerning both die jusdciability of economic, social, and cultural rights—at least as incorporated into Soudi Africa's Bill of Rights, sections 7 through 39 of its Constitution—and the concept of “minimum core obligations” as developed by the Committee.