The U.S. Constitution and U.S. law prohibits the use of unwarranted force or coercion against any person who is subject to interrogation, detention, or arrest. The Fifth Amendment to the United States Constitution includes protection against self-incrimination, which states that "o person...shall be compelled in any criminal case to be a witness against himself". This serves as the basis of the Miranda warning, which U.S. law enforcement personnel issue to individuals upon their arrest. Additionally, the U.S. Constitution's Eighth Amendment forbids the use of "cruel and unusual punishments," which is widely interpreted as prohibiting torture. Finally, 18 U.S.C. § 2340 "et seq." define and forbid torture committed by U.S. nationals outside the United States or non-U.S. nationals who are present in the United States. As the United States recognizes customary international law, or the law of nations, the U.S. Alien Tort Claims Act and the Torture Victim Protection Act also provides legal remedies for victims of torture outside of the United States. Specifically, the status of torturers under the law of the United States, as determined by a famous legal decision in 1980, "Filártiga v. Peña-Irala", 630 F.2d 876 (2d Cir. 1980), is that, "the torturer has become, like the pirate and the slave trader before him, hostis humani generis, an enemy of all mankind."