The case of the day is Miango v. Democratic Republic of Congo (D.D.C. 2020). Jacques Miango is a refugee from the Democratic Republic of Congo who lives in Maryland. In 2014, he participated at a protest across the street from the Capella Hotel in Washington. After President Kabila entered the hotel, Miango alleged that DRC security personnel rushed out of the hotel and assaulted the protesters, broke into Miango’s car, and stole his property. Miango sued, and the court entered default judgments against the DRC, President Kabila, and other DRC personnel. The individual defendants moved to vacate the judgment and dismiss the action. The court granted the motion as to Kabila on grounds of head-of-state immunity. The court found that the remaining defendants did…

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