Semi-Sweet: How a 1789 Statute Protects Domestic “Big Chocolate” Against Corporate Liability in International Human Rights Claims

22 Wake Forest J. Bus. & Intell. Prop. L. 100

In 1975, Judge Friendly described the Alien Tort Statute (“ATS”)
as a once “old but little used section” of the Judiciary Act of 1789—
proclaiming it was “a kind of legal Lohengrin . . . [from which] no one
seems to know whence it came.” Lohengrin, a German knight of
legend, rescued and married a woman in distress and requested that she
never ask his name or origin. When she asked him these questions, he
left and she “[fell] lifeless to the ground.”