We all know that Supreme Court decisions have impact, but they sometimes change litigation in unanticipated ways. What changes will the Court’s decision in Kiobel v. Royal Dutch Petroleum bring about in transnational human rights cases? Depending on what the Court holds, we may see a brave new world of transnational human rights litigation (1) in federal courts under state and foreign law, (2) in U.S. state courts under state and foreign law, and (3) in foreign courts under foreign law...Surprisingly, little attention has been paid to the impact that the Kiobel case may have on alternative fora, although it is of incredible practical importance. Indeed, the petitioners’ supplemental opening brief notes that “Respondents’ proposed categorical territorial limitation [of the ATS] would only frustrate Congress’s purpose by driving ATS tort cases into state courts rather than the federal forum the First Congress intended.”