The author first describes the 1994 armed conflict in Rwanda in which hundreds of thousands of Rwandan civilians were murdered. This is followed by a discussion of the legal implications of these massacres and an explanation of the concepts of criminality versus illegality under international law, direct versus indirect enforcement, and territorial versus universal jurisdiction. The norms of international law are then presented as they apply to the conflict in Rwanda, along with recent developments in their legal status. The article next deals briefly with the Statute of the International Criminal Tribunal for Rwanda, which is the international community's collective response to the massacres. The core of the article provides an overview of states' individual practices related to the Rwandan massacres. The countries that took some legal action independent of any request by the International Criminal Tribunal for Rwanda are Belgium, Canada, France, and Switzerland. The article concludes that in each of the involved countries, the judicial authorities were slow to act, and their initiatives followed the establishment of the International Tribunal for Rwanda. Nevertheless, important precedents have been set in each country. The possibility in some states for private citizens to initiate criminal proceedings for crimes that give rise to universal jurisdiction opens extraordinary avenues for human rights litigators. 159 notes