Cisco Systems, Inc. v. Doe · ¶17

While the Courts of Appeals wrestled with novel ATS suits, Congress enacted a related cause of action. The Torture Victim Protection Act of 1991 allows certain victims who are tortured or killed to recover damages against the perpetrators. 106 Stat. 73, note following 28 U. S. C. §1350. But because many human rights abuses fall outside the TVPA, plaintiffs continued pressing courts to fashion rights of action under the ATS.

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