Western states protect human rights -- at least from their own perspective. However, one reason why this commitment to human rights is questioned by much of the rest of the world is that Europe and the United States have both come to apply a set of double standards, following one set of legal standards at home, but a completely different set of standards (and, arguably, no standards at all) in their dealings with those beyond their territorial borders. In Bankovic v. Belgium, the European Court of Human Rights held that the European Convention is “primarily territorial.” In that way, the Contracting States are not bound by the provisions of the Convention in their dealings with those outside of Europe. The American perspective appears to be different but in reality it is not. In Rasul v. Bush, the U.S. Supreme Court held that the “enemy combatants” in the U.S. military prison at Guantanamo Bay, Cuba were deserving of protection under United States law. In that way, the U.S. seems to extend human rights protection beyond its borders in a way that European states do not. The problem with Rasul is that there is no other place in the world where the U.S. government exercises anywhere near the kind of “sovereignty” that it does at Guantanamo Bay. Because of this, in all likelihood the United States will come to adopt the same kind of legal apartheid system that the European states have developed. For Western states, human rights protection essentially begins – but also ends – at their own national borders. The larger point is that this approach to “human rights” will seriously undermine the entire human rights enterprise.