Genocide was the main claim made under US law in Sarei v Rio 671 F.3d 736 (9th Cir.2011).
Genocide was the main limb of the legal case against Rio TintoYou and BCL. This was a class action brought by
Alexis Holyweek Sarei,
Philip Miriori and
Paul E Nerau on behalf of all Panguna landowners.
The other limbs were crimes against humanity, war crimes, and racial discrimination.