On June 12, 2012, the International Court of Justice ("ICJ" or the "Court") ordered the Republic of the Congo ("DRC") to pay the Republic of Guinea ("Guinea") U.S. $95,000 in compensation for material and non-material injury to Guinea's national Ahmadou Sadio Diallo. The Judgment is notable for several reasons. First, the mere fact that the Court fixed an amount of compensation owned to Guinea is relevant, as this is only the second time in the history of the Court that such a measure was adopted. Second, in reaching its decision, the Court relied heavily on decisions of other international courts and tribunals to determine the amount of compensation. By doing so, the Court aligned itself with other courts' precedent and marginalized fears of fragmentation in international law. Third, the Court's reasoning to award U.S. $95,000 rather than the twelve million dollars requested by Guinea is also significant.

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