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The Judgment of the International Court of Justice (ICJ) in the LaGrand case has not to date resulted in a discernible improvement in United States compliance with the Vienna Convention on Consular Relations.2 The gross deficiencies of U.S. practice regarding consular access under Article 36 of the Convention are a sad but telling reflection of the unreality of international law in the United States today. The lessons from LaGrand are varied and important.

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