Cisco Systems, Inc. v. Doe · ¶116
What is clear is that the majority today forecloses future reliance on Sosa and shuts the courthouse doors to almost any claimed violation of international law under the ATS. That includes torture. See, e.g., Filartiga v. Pena-Irala, 630 F. 2d 876, 878 (CA2 1980) (ATS suit brought by plaintiff alleging that his son had been kidnapped and tortured to death in retaliation for the plaintiff ’s political beliefs). It includes forced labor. See, e.g., Licea v. Curacao Drydock Co., 584 F. Supp. 2d 1355, 1359 (SD Fla. 2008) (ATS suit alleging that the defendant trafficked Cubans to Curacao, held them in captivity, and forced them to work repairing ships and oil platforms). It also includes perhaps the most universally condemned crime in the modern era: genocide. See, e.g., Kadic v. Karadzic, 70 F. 3d 232, 236–237 (CA2 1995) (ATS suit alleging “brutal acts of rape, forced prostitution, forced…Read in context ›
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