About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

LOG IN
LOG IN


93 Va. L. Rev. Brief 1 (2007-2008)

handle is hein.journals/inbrf93 and id is 1 raw text is: VIRGINIA LAW REVIEW IN BRIEF VOLUME 93 MARCH 22,2007 PAGES 1-14 ESSAY INTERNATIONAL HUMAN RIGHTS IN AMERICAN COURTS William A. Fletcher* N 1984, in Tel-Oren v. Libyan Arab Republic, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal of an international human rights case. In the first sentence of his concurring opinion, Judge Edwards wrote, This case deals with an area of the law that cries out for clarification by the Supreme Court.' Twenty years later, the Su- preme Court decided Sosa v. Alvarez-Macham. What, if anything, has the Court clarified? Judge Edwards referred to tort suits brought by aliens for viola- tions of the law of nations under the Alien Tort Statute (ATS), 28 U.S.C. § 1350. The ATS originated as Section 9 of the Judiciary Act of 1789. The modern text is little changed from the original. It reads: . Judge, United States Court of Appeals for the Ninth Circuit; Richard W. Jennings, Jr., Professor of Law, Emeritus, University of California, Berkeley, School of Law (Boalt Hall). Tel-Oren v. Libyan Arab Republic, 726 F.2d 774, 775 (D.C. Cir. 1984) (Edwards, J., concurring). '542 U.S. 692 (2004).