In Kiobel v. Royal Dutch Petroleum Co., 133 S.Ct. 1659 (2013), the U.S. Supreme Court addressed the applicability of the Alien Tort Statute (ATS) to alleged violations of international law committed by multinational corporations overseas. Although the Supreme Court rejected the claims in Kiobel because of the presumption against the extraterritorial application of statutes such as the ATS, the Supreme Court did not completely slam the door shut on ATS litigation. What types of ATS cases survive Kiobel will...
