Litigation in domestic courts is only one of many ways to promote and protect international human rights, but it has received much attention from lawyers, scholars, governments, and nongovernmental organizations.'Attention has focused above all on litigation in the US federal courts under the Alien Tort Statute (ATS), 2 which provides that"[t] he district courts shall have original jurisdiction of any civil action by an alien for a tort only, committed in violation of the law of nations or a treaty of the United States." 3 Originally adopted by the US Congress as part of the Judiciary Act of 1789, 4 it was not until the Second Circuit's