Since 1993, more than 400 women have been murdered in Ciudad Judrez,

Mexico. Few, if any of these crimes have been solved, largely because local

Mexican officials have failed to adequately investigate them. This Article

argues that femicide victims could hold those officials civilly liable as third

parties for these femicides in U.S. federal courts under the Alien Tort

Statute (ATS). Although aiding and abetting liability is the most common

form of third-party liability sought in ATS cases, several high profile

cases have challenged whether it should exist under the ATS. The author

agrees with many courts and scholars that aiding and abetting liability

should be sustained. However, the author argues that none of the

previously proposed standards for aiding and abetting would reach the

Mexican officials. Instead, the author proposes "acquiescence to torture"

as an innovative form of third-party liability. Acquiescence to torture, as

it has been defined in U.S. non-refoulement cases, would broaden the

scope of the ATS to allow a suit against Mexican officials for their failure

to adequately prevent or investigate the femicides in Ciudad Judrez.