There has also been a case where an American citizen was held accountable for atrocities committed during Liberia's Second Civil War. Chuckie Taylor, American son of Charles Taylor, was sentenced in 2009 in the U.S. for torture he committed during the Second Liberian Civil War. He was tried for torture, and not immigration-related crimes, as a U.S. citizen and was the first-ever to be tried under 18 U.S.C.§ 2340, or the “Torture Act,” which states an act of torture committed outside the U.S. by a U.S. national is punishable by law.