During the 1988 trial of Mutula Shakur, a self-described soldier for the "Republic of Afrika" accused by the United States government of murdering police and robbery in New York, the defense argued that Shakur was immune from prosecution on the grounds that, pursuant to the terms of Protocol I to the Geneva Convention, he should be treated as a prisoner of war.

CENTERFORSECURITYPOLICY: Center for Security Policy | The Senate Should Send The PLO A Message: There??s No Hijacking International Law