[PDF] Esther Kiobel, et al. v. Royal Dutch Petroleum, et al. - Petitioners' Supplemental Reply Brief
Following a comprehensive review of the text, history and purpose of the Alien Tort Statute (“ATS”), this Court held that the ATS is a jurisdictional statute authorizing federal courts to remedy certain universally proscribed violations of the law of nations. Sosa v. Alvarez-Machain…In particular, this Court endorsed the line of cases following Filartiga v. Pena-Irala…which consistently applied the ATS to human rights violations occurring on foreign soil…Respondents and their amici essentially seek to reverse Sosa, to overrule Filartiga and its progeny, and to nullify the ATS as a means of redressing universally condemned human rights violations…[T]he First Congress passed the ATS so that our country would not become a safe haven for pirates or other enemies of mankind. Respondents offer no persuasive reason to abandon this Nation’s commitments to human rights and the enforcement of the law of nations.