Part 1 of this Note will attempt a definition of terrorism to determine whether the Tel-Oren attack was a terrorist act. Part II will discuss whether terrorism is a tort in violation of the law of nations for purposes of Alien Tort Statute jurisdiction. Part III will examine United States cases interpreting the term "violation of the law of nations" in the Alien Tort Statute and will then analyze the district court's opinion in Tel-Oren, particularly its holding that Alien Tort Statute jurisdiction requires that the law of nations or a treaty confer a private right of action upon individuals. Finally, Part IV will consider the implications of a court of appeals reversal in Tel-Oren and a holding that jurisdiction lies under the Alien Tort Statute.
Eileen Rose Pollock,
Terrorism as a Tort in Violation of the Law of Nations,
6 Fordham Int'l L.J. 236
Available at: http://ir.lawnet.fordham.edu/ilj/vol6/iss1/9