Tort Statute (28 U.S.C. § 1350; ATS), also called
Tort Claims Act (ATCA), is a section of the United States
Code that reads: "The district courts shall have original jurisdiction
of any civil action by an alien for a tort only, committed in
violation of the law of nations or a treaty of the United States."
Since 1980, courts have interpreted this statute to allow foreign
citizens to seek remedies in U.S. courts for human-rights violations
for conduct committed outside the United States.
2.1 Filartiga v. Pena-Irala
2.2 Sosa v. Alvarez-Machain
2.3 Jesner v. Arab Bank, PLC
2.4 Ongoing controversy
3 Scope of the statute
3.1 "Violation of the Law of Nations"
3.2 Corporate liability under the statute
4 Prominent cases under the statute
4.1 Kiobel v. Royal Dutch Petroleum
4.2 Sarei v. Rio Tinto
4.3 Kpadeh v. Emmanuel
4.4 Presbyterian Church of Sudan v. Talisman Energy, Inc.
4.5 Sinaltrainal v. Coca-Cola Company
4.6 Bowoto v. Chevron Corp.
Wang Xiaoning v. Yahoo!
4.8 Doe v. Unocal
6 External links
The district courts shall have original jurisdiction of any civil
action by an alien for a tort only, committed in violation of the law
of nations or a treaty of the United States.
The ATS was part of the Judiciary Act of 1789. There is little
surviving legislative history regarding the Act, and its original
meaning and purpose are uncertain. However, scholars have
surmised that the Act was intended to assure foreign governments that
the U.S. would act to prevent and provide remedies for breaches of
customary international law, especially breaches concerning diplomats
The ATS may have been enacted in response to a number of international
incidents caused by the non-availability of remedies for foreign
citizens in the United States. For example, the peace treaty ending
American Revolution provided for the satisfaction of debts to
British creditors. The refusal of some states to enforce the payment
of such debts prompted Great Britain to threaten to retaliate. In
1784, French diplomat
François Barbé-Marbois was assaulted, but no
remedy was available to him. The incident was notorious
internationally and prompted Congress to draft a resolution asking the
states to allow suits in tort for the violation of the law of nations.
However, few states enacted such a provision, and Congress
subsequently included the ATS in the Judiciary Act of 1789.
From 1789 until 1980, only two courts based jurisdiction on the
Filartiga v. Pena-Irala
Main article: Filártiga v. Peña-Irala
In 1980, the U.S. Court of Appeals for the Second Circuit decided
Filártiga v. Peña-Irala, which "paved the way for a new
conceptualization of the ATS". In Filartiga, two Paraguayan
citizens resident in the U.S., represented by the Center for
Constitutional Rights, brought suit against a Paraguayan former police
chief who was also living in the United States. The plaintiffs
alleged that the defendant had tortured and murdered a member of their
family, and they asserted that U.S. federal courts had jurisdiction
over their suit under the ATS. The district court dismissed for lack
of subject-matter jurisdiction, holding that the "law of nations" does
not regulate a state's treatment of its own citizens.
The U.S. Court of Appeals for the Second Circuit reversed the decision
of the district court. First, it held that the ATS, which allowed
jurisdiction in the federal courts over a suit between two aliens, was
a constitutional exercise of Congress's power, because "the law of
nations...has always been part of the federal common law", and thus
the statute fell within federal-question jurisdiction. Second, the
court held that the contemporary law of nations had expanded to
prohibit state-sanctioned torture. The court found that multilateral
treaties and domestic prohibitions on torture evidenced a consistent
state practice of proscribing official torture. The court similarly
United Nations declarations, such as the Universal
Declaration on Human Rights, manifested an expectation of adherence to
the prohibition of official torture. The court therefore held that the
right to be free from torture had become a principle of customary
international law. However, one of the judges on the panel hearing the
case later wrote that Filartiga "should not be misread or exaggerated
to support sweeping assertions that all (or even most) international
human rights norms found in the Universal Declaration or in
international human rights treaties have ripened into customary
international law enforceable in the domestic courts".
Since Filartiga, jurisdiction under the ATS has been upheld in dozens
Sosa v. Alvarez-Machain
Main article: Sosa v. Alvarez-Machain
The first U.S. Supreme Court case to directly address ATS is Sosa v.
Alvarez-Machain (2004). The plaintiff in Sosa, Alvarez, brought a
claim under ATS for arbitrary arrest and detention. Alvarez had been
indicted in the United States for torturing and murdering a Drug
Enforcement Administration officer. When the U.S. was unable to secure
Alvarez's extradition, it paid Sosa, a Mexican national, to kidnap
Alvarez and bring him into the U.S. Alvarez claimed that his "arrest"
by Sosa was arbitrary because the warrant for his arrest only
authorized his arrest within the U.S. The U.S. Court of Appeals for
the Ninth Circuit held that Alvarez's abduction constituted arbitrary
arrest in violation of international law.
The Supreme Court reversed and clarified that ATS did not create a
cause of action, but instead merely "furnish[ed] jurisdiction for a
relatively modest set of actions alleging violations of the law of
nations." Such actions must "rest on a norm of international
character accepted by the civilized world and defined with a
specificity comparable to the features of the 18th-century paradigms
we have recognized." Although the scope of ATS is not limited to
violations of international law recognized in the 18th century, with
respect to recognizing contemporary international norms, the court's
opinion stated that "the judicial power should be exercised on the
understanding that the door is still ajar subject to vigilant
In Alvarez's case, "a single illegal detention of less than a day,
followed by the transfer of custody to lawful authorities and a prompt
arraignment, violates no norm of customary international law so well
defined as to support the creation of a federal remedy."
Jesner v. Arab Bank, PLC
On April 3, 2017, the Supreme Court agreed to hear the case Jesner v.
Arab Bank, PLC, which asks the question: "Whether the Alien Tort
Statute... categorically forecloses corporate liability."
Exercising legal jurisdiction in the United States over matters that
occurred abroad is a controversial practice and some have suggested
that Congress eliminate it. Others believe that a multilateral
solution, including through either the Organization for Economic
Cooperation and Development or the UN, would be more appropriate.
Scope of the statute
"Violation of the Law of Nations"
The Supreme Court held in
Sosa v. Alvarez-Machain
Sosa v. Alvarez-Machain that the ATS
provides a cause of action for violations of international norms that
are as "specific, universal, and obligatory" as were the norms
prohibiting violations of safe conducts, infringements of the rights
of ambassadors, and piracy in the 18th century. Courts have found
torture; cruel, inhuman, or degrading treatment; genocide; war crimes;
crimes against humanity; summary execution; prolonged arbitrary
detention; and forced disappearance to be actionable under the
Since Sosa, courts have struggled to define the level of specificity
required for a norm to be actionable under the ATS. For example,
subsequent to Sosa, the U.S. Court of Appeals for the Eleventh Circuit
overturned prior lower-court decisions that had found cruel, inhuman,
or degrading treatment actionable, noting that Sosa repudiated the
International Covenant on Civil and Political Rights
International Covenant on Civil and Political Rights as a source of
law under the ATS. Similarly, courts have held that economic,
social, and cultural rights are too indeterminate to satisfy Sosa's
specificity requirement. For example, in Flores v. Southern Peru
Copper Corp., the Second Circuit stated that the rights to life and to
health are too indeterminate to constitute a cause of action under the
The U.S. District Court for the Northern District of California,
however, has held that the limits of a norm need not be defined with
particularity to be actionable; rather, the norm need only be so
defined that the particular acts upon which a claim is based certainly
fall within the bounds of the norm. In Doe v. Qi, the court
stated, "The fact that there may be doubt at the margins – a
fact that inheres in any definition – does not negate the
essence and application of that definition in clear cases." The court
also described how to determine whether specific actions fall within
the proscriptions of an international norm, holding that the actions
alleged should be compared with actions that international
adjudicatory bodies have found to be proscribed by the norm in
question. It therefore examined decisions by institutions such as the
Human Rights Committee, the European Court of Human Rights, and the
African Commission on Human and Peoples' Rights to determine that
pushing, hitting, and choking a plaintiff during one day of
incarceration did not constitute cruel, unusual, or degrading
treatment, whereas forcing a hand into a plaintiff's vagina did
constitute cruel, inhuman, or degrading treatment.
Corporate liability under the statute
As of October 2011, there was a circuit split regarding whether
corporations, as opposed to natural people, could be held liable under
the ATS. In 2010 the Second Circuit Court of Appeals held in Kiobel v.
Royal Dutch Petroleum Co. that "customary international law has
steadfastly rejected the notion of corporate liability for
international crimes" and thus that "insofar as plaintiffs bring
claims under the ATS against corporations, plaintiffs fail to allege
violations of the law of nations, and plaintiffs' claims fall outside
the limited jurisdiction provided by the ATS". However, in 2011,
the Seventh Circuit Court of Appeals, the Ninth Circuit Court of
Appeals, and the D.C. Circuit Court of Appeals all ruled that
corporate liability is possible under the statute. On April 17,
Kiobel v. Royal Dutch Petroleum
Kiobel v. Royal Dutch Petroleum Co., the U.S. Supreme Court
issued a decision affirming the Second Circuit Court of Appeals but on
different grounds, holding that the ATS did not create jurisdiction
for a claim regarding conduct occurring outside the territory of the
United States, leaving the question of corporate liability unresolved.
Prominent cases under the statute
Kiobel v. Royal Dutch Petroleum
Main article: Kiobel v. Royal Dutch Petroleum
The plaintiffs in Kiobel were citizens of
Nigeria who claimed that
Dutch, British, and Nigerian oil-exploration corporations aided and
Nigerian government during the 1990s in committing
violations of customary international law. The plaintiffs claimed
Royal Dutch Shell
Royal Dutch Shell compelled its Nigerian subsidiary, in
cooperation with the Nigerian government, to brutally crush peaceful
resistance to aggressive oil development in the
Ogoni Niger River
Delta. Plaintiffs sought damages under the ATS. The defendants
moved to dismiss based on a two-pronged argument. First, they argued
that customary international law itself provides the rules by which to
decide whether conduct violates the law of nations where non-state
actors are alleged to have committed the wrong in question. Second,
they contended that no norm has ever existed between nations that
imposes liability upon corporate actors. On September 29, 2006, the
district court dismissed the plaintiffs' claims for aiding and
abetting property destruction; forced exile; extrajudicial killing;
and violation of the rights to life, liberty, security, and
association. It reasoned that customary international law did not
define those violations with sufficient particularity. The court
denied the defendants' motion to dismiss with respect to the remaining
claims of aiding and abetting arbitrary arrest and detention; crimes
against humanity; and torture or cruel, inhuman, and degrading
treatment. The district court then certified its entire order for
interlocutory appeal to the Second Circuit based on the serious nature
of the questions at issue.
In a 2–1 decision issued on September 17, 2010, the U.S. Court of
Appeals for the Second Circuit held that corporations cannot be held
liable for violations of customary international law, finding that:
(1) under both U.S. Supreme Court and Second Circuit precedents over
the previous 30 years that address ATS suits alleging violations of
customary international law, the scope of liability is determined by
customary international law itself; (2) under Supreme Court precedent,
the ATS requires courts to apply norms of international law—and not
domestic law—to the scope of defendants' liabilities. Such norms
must be "specific, universal and obligatory"; and (3) under
international law, "corporate liability is not a discernible—much
less a universally recognized—norm of customary international
law", that the court could apply to the ATS, and that the
plaintiffs' ATS claims should indeed be dismissed for lack of subject
Kiobel petitioned the Supreme Court for review of the Second Circuit's
decision, and this was granted on October 17, 2011. Oral arguments
were held on February 28, 2012, The arguments received
considerable attention in the legal community. Unexpectedly,
the Supreme Court announced on March 5, 2012, that it would hold
additional argument on the case during the October 2012 term, and
directed the parties to file new briefs on the question "Whether and
under what circumstances the Alien
Tort Statute, 28 U.S.C. § 1350,
allows courts to recognize a cause of action for violations of the law
of nations occurring within the territory of a sovereign other than
the United States." Reargument of the case occurred on October 1,
On April 17, 2013 the U.S. Supreme Court held that the ATS does not
apply outside the United States.
Sarei v. Rio Tinto
In 2000, residents of the island of Bougainville in Papua New Guinea
brought suit against multinational mining company Rio Tinto. The
lawsuit is based on a 1988 revolt against Rio Tinto, and the
plaintiffs allege that the
Papua New Guinea
Papua New Guinea government, using Rio
Tinto helicopters and vehicles, killed about 15,000 people in an
effort to put down the revolt. On October 25, 2011, the Ninth
Circuit Court of Appeals, sitting en banc, issued a divided opinion
holding that certain claims against a foreign corporation implicating
the conduct of a foreign government on foreign soil could proceed
under the ATS. The company filed a petition for a writ of certiorari
in the Supreme Court for review of the decision; on April 22, 2013,
the Supreme Court sent the case back to the Ninth Circuit for further
consideration in the light of its decision in the Kiobel case (above).
Kpadeh v. Emmanuel
Main article: Charles McArthur Emmanuel
Charles McArthur Emmanuel (also known as "Chuckie Taylor" or
"Taylor Jr."), the son of Charles Taylor, former President of
Liberia, was the commander of the infamously violent
Anti-Terrorist Unit (ATU), commonly known in Liberia as the "Demon
Forces". In 2006, U.S. officials arrested Taylor Jr. upon entering the
U.S. (via the Miami International Airport) and the Department of
Justice later charged him based on torture he committed in
Liberia. He was convicted of multiple counts of torture and
conspiracy to torture and was sentenced to 97 years in prison.
The World Organization for Human Rights USA and the Florida
International University College of Law filed a civil suit in the
Southern District of Florida on behalf of five of Taylor Jr.'s victims
pursuant to the Alien
Tort Statute and the
Torture Victim Protection
Act. The plaintiffs won by default judgment as to liability on all
counts, and in February 2010, following trial on damages at which
Taylor appeared, the court found Taylor liable to the plaintiffs for
damages of over $22 million.
Presbyterian Church of Sudan v. Talisman Energy, Inc.
On October 2, 2009, the Court of Appeals for the Second Circuit, in
Presbyterian Church of Sudan v. Talisman Energy, Inc., held that "the
mens rea standard for aiding and abetting liability in Alien Tort
Statute actions is purpose rather than knowledge alone." In this
case, which involves allegations against a Canadian oil company
concerning its purported assistance to the government in Sudan in the
forced movement of civilians residing near oil facilities, the court
concluded that "plaintiffs have not established Talisman's purposeful
complicity in human rights abuses." In reaching that conclusion, the
Second Circuit stated that "the standard for imposing accessorial
liability under the Alien
Tort Statute must be drawn from
international law; and that under international law a claimant must
show that the defendant provided substantial assistance with the
purpose of facilitating the alleged offenses."
Sinaltrainal v. Coca-Cola Company
On August 11, 2009, the Court of Appeals for the Eleventh Circuit
issued a decision in Sinaltrainal v. Coca-Cola Company. In this
case, plaintiffs alleged that Coca-Cola bottlers in Colombia
collaborated with Colombian paramilitary forces in "the systematic
intimidation, kidnapping, detention, torture, and murder of Colombian
trade unionists." However, the district court dismissed the complaint
and the Eleventh Circuit upheld that ruling. In doing so, the Eleventh
Circuit relied upon the Supreme Court's recent Ashcroft v. Iqbal
decision in addressing the adequacy of the complaint, which must
have "facial plausibility" to survive dismissal, and noted that Rule 8
of the Federal Rules of Civil Procedure demands "more than an
unadorned, the-defendant-unlawfully-harmed-me accusation." The
Eleventh Circuit then applied the Iqbal standard to plaintiffs'
allegations against Coca-Cola and held that they were insufficient to
Bowoto v. Chevron Corp.
Main article: Bowoto v. Chevron Corp.
Nigerian villagers brought claims against Chevron Corp. regarding
events that occurred on a Chevron offshore drilling platform in 1998,
when Nigerian soldiers suppressed a protest against Chevron's
environmental and business practices. The protesters, with the help of
nonprofit organizations including the Center for Constitutional
Rights, the Public Interest Lawyers Group, and EarthRights
International, brought claims for wrongful death, torture, assault,
battery, and negligence against Chevron, alleging that the company had
paid the soldiers that landed on the platform and were therefore
liable for the actions that they took. In December 2008, a jury found
that Chevron was not liable.
Wang Xiaoning v. Yahoo!
Main article: Wang Xiaoning
In 2007, the World Organization for Human Rights USA filed a lawsuit
Yahoo! on behalf of Chinese dissidents
Wang Xiaoning and Shi
Tao (Guao Quingsheng), claiming jurisdiction under the ATS.
According to the complaint, Wang and Shi Tao used
Yahoo! accounts to
share pro-democracy material, and a Chinese subsidiary of
the Chinese government identifying information that allowed
authorities to identify and arrest them. The Complaint alleges
that the plaintiffs were subjected to "torture, cruel, inhuman, or
other degrading treatment or punishment, arbitrary arrest and
prolonged detention, and forced labor."
Yahoo! settled the case in November 2007 for an undisclosed amount of
money, and it agreed to cover the plaintiff's legal costs as a part of
the settlement. In a statement released after the settlement was made
Yahoo! said that it would "provide 'financial, humanitarian
and legal support to these families' and create a separate
'humanitarian relief fund' for other dissidents and their
Doe v. Unocal
Main article: Doe v. Unocal
In September 1996, four Burmese villagers filed suit against Unocal
and its parent company, the Union Oil Company of California; in
October 1996, another fourteen villagers also brought suit. The
suits alleged various human rights violations, including forced labor,
wrongful death, false imprisonment, assault, intentional infliction of
emotional distress and negligence, all relating to the construction of
the Yadana gas pipeline project in Myanmar, formerly Burma.
In 2000, the district court dismissed the case on the grounds that
Unocal could not be held liable unless
Unocal wanted the military to
commit abuses, and that plaintiffs had not made this showing.
Plaintiffs appealed and ultimately, shortly prior to when the case was
to be argued before the Ninth Circuit en banc court in December 2004,
the parties announced that they had reached a tentative settlement.
Once the settlement was finalized in March 2005, the appeal was
withdrawn and the district court opinion from 2000 was also vacated.
According to a joint statement released by the parties, while the
specific terms were confidential, "the settlement will compensate
plaintiffs and provide funds enabling plaintiffs and their
representatives to develop programs to improve living conditions,
health care and education and protect the rights of people from the
pipeline region. These initiatives will provide substantial assistance
to people who may have suffered hardships in the region."
^ "28 USC § 1350 - Alien's action for tort LII / Legal Information
Institute". Law.cornell.edu. Retrieved 2012-06-22.
^ Ch. 20, § 9, 1 Stat. 73 (1789).
^ Carolyn A. D'Amore, Note,
Sosa v. Alvarez-Machain
Sosa v. Alvarez-Machain and the Alien Tort
Statute: How Wide Has the Door to Human Rights Litigation Been Left
Open?, 39 Akron L. Rev. 593, 596 (2006); William R. Casto, The Federal
Courts' Protective Jurisdiction Over Torts Committed in Violation of
the Law of Nations, 18 Conn. L. Rev. 467, 468-69 (1985-1986).
^ "Archived copy". Archived from the original on September 29, 2011.
Retrieved 2009-11-20. .
^ Hufbauer, Gary Clyde; Mitrokostas, Nicholas K. (2003). Awakening
Monster: The Alien
Tort Statute of 1789. Washington, D.C.: Institute
for International Economics. ISBN 978-0-88132-366-5.
^ Haberstroh, John (2004). The Alien
Tort Claims Act & Doe v.
Unocal: A Paquete Habana Approach to the Rescue, 32 Denv. J. Int'l L.
& Pol'y 231, 239–41.
^ Hufbauer, Gary Clyde; Mitrokostas, Nicholas K. (2004). International
Implications of the Alien
Tort Statute. 16 St. Thomas L. Rev. 607,
^ 630 F.2d 876 (2d Cir. 1980); Richard B. Lillich, Invoking
International Human Rights Law in Domestic Courts, 54 U. Cin. L. Rev.
^ Filartiga v. Pena-Irala, 630 F.2d 876, 885 (2d Cir. 1980).
^ Lillich, supra note 8, at 401–02.
^ Beth Stephens, Judicial Deference and the Unreasonable Views of the
Bush Administration, 33 Brooklyn J. Int'l L. 773, 813 (2008).
^ Sosa v. Alvarez-Machain, 542 U.S. 692, 720 (2004).
Sosa v. Alvarez-Machain
Sosa v. Alvarez-Machain at 725; see also Pamela J. Stephens,
Spinning Sosa: Federal Common Law, the Alien
Tort Statute, and
Judicial Restraint, 25 B.U. Int'l L.J. 1, 32-33 (Spring, 2007).
Sosa v. Alvarez-Machain
Sosa v. Alvarez-Machain at 729.
Sosa v. Alvarez-Machain
Sosa v. Alvarez-Machain at 738.
^ "Jesner v. Arab Bank, PLC - SCOTUSblog". SCOTUSblog. Retrieved
^ Bradley, Curtis A.; Goldsmith, Jack L. (2009-04-19). "Rights Case
Gone Wrong". The Washington Post. Retrieved April 23, 2010.
^ Medish, Mark C.; Lucich, Daniel R. (June 1, 2009). "Trying an Old
Law". New York Times. Retrieved April 23, 2010.
^ D'Amore, supra note 2.
^ Pamela J. Stephens, supra note 10, at 5.
^ Henry J. Steiner et al., International Human Rights in Context
1195-98 (3d ed. 2008), ISBN 978-0-19-927942-5.
^ Aldana v. Del Monte Fresh Produce, 416 F.3d 1242, 1247 (11th Cir.
^ 414 F.3d 233 (2d Cir. 2003).
^ Doe v. Qi, 349 F.Supp.2d 1258 (N.D.Cal. 2004).
Kiobel v. Royal Dutch Petroleum
Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111, 120 (2d Cir.
^ Flomo v. Firestone Nat. Rubber Co., LLC, 643 F.3d 1013, 1021 (7th
^ Doe VIII v. Exxon Mobil Corp., No. 09-7125 (D.C. Cir. 2011).
^ a b Kiobel v. Royal Dutch Petroleum, 621 F.3d 111 (2d Cir. 2010).
^ Kearney, Colin (January 1, 2011). "Corporate Liability Claims Not
Actionable Under Alien
Tort Statute" (PDF). Suffolk Transnational Law
Review. Retrieved January 3, 2013.
^ Kerschberg, Ben (December 2, 2010). "Corporate Executives: Get Ready
for a Billion Dollar Lawsuit". The Blog of The Huffington Post.
Retrieved March 5, 2012.
^ February 28, 2012
^ Denniston, Lyle (October 17, 2011). "Court To Rule on Suing
Corporations and PLO". SCOTUSblog. Retrieved October 16, 2011.
^ Lithwick, Dahlia (February 28, 2012). "Justice on the High Seas: The
Supreme Court Says Corporations Have a Right to Free Speech. But Can
They Get Away with Murder?". Slate. Retrieved February 29, 2012.
^ Weiss, Peter (February 28, 2012). "The Question Before the US
Supreme Court in Kiobel v Shell – If Corporations Have the Same
Rights as People To Make Political Donations, Then Surely They Also
Have Human Rights Obligations?". The Guardian. Retrieved March 5,
^ Denniston, Lyle (March 5, 2012). "Kiobel To Be Reargued".
SCOTUSblog. Retrieved March 5, 2012.
^ "Kiobel v. Royal Dutch Petroleum". SCOTUSblog. Retrieved 15
^ Sacks, Mike (October 25, 2011). "9th Circuit: Corporations Can Be
Sued for Human Rights Violations Abroad". The Huffington Post.
Retrieved March 5, 2012.
^ "090109washington_lg.jpg." U.S. Immigration and Customs Enforcement.
Retrieved August 27, 2009. Archived May 7, 2009, at the Wayback
^ [dead link] Ex-"Prisoner: Taylor's Son Laughed at Torture" Archived
2008-12-18 at the Wayback Machine.. CNN. September 30, 2008.
^ "Roy Belfast Jr. aka Chuckie Taylor Indicted on
Department of Justice". December 6, 2006.
^ "Roy Belfast Jr. A/K/A Chuckie Taylor Convicted on
Department of Justice Press Release". October 30, 2008.
^ "Roy Belfast, Jr., A/K/A Chuckie Taylor, Sentenced on Torture
Charges, Department of Justice Press Release". December 9, 2009.
^ "Archived copy". Archived from the original on 2010-06-12. Retrieved
^ Harris, Theresa. "Human Rights USA: Chuckie Taylor". Retrieved 17
^ Rufus Kpadeh et al. v. Charles McArthur Emmanuel, No. 09-20050-civ
(S.D. Fla. Feb. 5, 2010).
^ "Archived copy" (PDF). Archived from the original (PDF) on
2011-06-13. Retrieved 2009-10-28.
^ Reddall, Braden (December 1, 2008). "Jury Clears Chevron of Charges
Nigeria Clash". Reuters. Retrieved March 5, 2012.
^ "Second Amended Complaint".
^ Cha, Ariana Eunjung; Diaz, Sam (April 19, 2007). "Advocates Sue
Yahoo in Chinese
Torture Case". The Washington Post. Retrieved March
^ Perez, Juan Carlos (November 14, 2007). "Yahoo Settles Chinese
Dissident Lawsuit". IDG News (via PC World). Retrieved March 5,
^ Doe I v.
Unocal Corp., 395 F.3d 932, 942-43 (9th Cir. 2002)
^ "Archived copy". Archived from the original on 2009-07-15. Retrieved
2012-10-04. EarthRights Int'l,
Doe v. Unocal
Doe v. Unocal Settlement
Corporate Liability Claims Not Actionable Under Alien
Tort Statute in
the Suffolk Transnational Law Review
Debate over Founders' original intent with the Alien
Tort Claims Act
in the Harvard Law Record
Tort Statute Today (last updated Feb. 2011)
Tort Statute Cases Resulting in Plaintiff Victories
Tort Statute: From Corporate Personhood to Corporate Humanity
(TedX Hampshire College)