Many articles have been written on the Armenian Genocide, both in the context of how to obtain Turkish recognition and how to obtain monetary relief in the courts of the United States. This Article summarizes the issues with the Movsesian III holding with regards to lack of precedent and the Ninth Circuit’s failure to follow the Supreme Court’s trend of limiting preemption. This Article then analyzes related decisions from four other circuits, demonstrating a clear circuit split on judicial understanding of the 5-4 Supreme Court ruling in Garamendi. This Article provides a roadmap to a friendly forum for victims of the Armenian Genocide, or victims of any other similar foreign tragedy, who seek redress in the American judicial system. By focusing their efforts on litigating and passing legislation in these friendly circuits, individuals seeking justice may realize better results than the victims and plaintiffs in the Movsesian line of cases.



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