id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-5119	Estes, Benjamin	May the Fourth Be with You: Charting the Future of Corporate Liability Under the Alien Tort Statute After Jesner v. Arab Bank	2019	53	.pdf	application/pdf	18665	686	47	It stated that “the cautionary language of Sosa would be little more than empty rhetoric” if foreign corporations faced ATS liability.81 Under this view, imposing ATS liability on foreign corporations could result in significant international friction with the corporations’ home nations, reinforcing the need for courts to defer to the political branches in the area of foreign relations, since that is traditionally not the judiciary’s province.82 Justice Kennedy reached the second Sosa question because there was “sufficient doubt” on the first question to merit doing so, but in his discussion of the first question, he seemed to indicate that he sided with Kiobel I (though this part of the opinion did not carry a majority of the Court).83 In Kiobel I, writing for the Second Circuit, Judge Cabranes interpreted international law and Sosa’s footnote 20 to mean that corporate ATS liability could only exist if corporate liability for human rights violations was itself a universally recognized norm of international law.84 Justice Kennedy did not decide 78 Id. at 1398 (emphasis added). However, the Supreme Court has in recent years restricted the scope of corporate ATS liability.	cache/cblr-5119.pdf	txt/cblr-5119.txt