Last year, a divided Second Circuit decided Kiobel v. Royal Dutch Petroleum, which ended three decades of abusive application of the Alien Tort Statute—an eighteenth-century federal law—against innocent-bystander corporate defendants through application of amorphous concepts of international law. The losing plaintiffs have submitted a certiorari petition noting the circuit split with the Eleventh Circuit. [SCOTUSblog via Bashman; Jackson]