Sosa v. Alvarez-Machain

Sosa v. Alvarez-Machain
Argued March 30, 2004
Decided June 29, 2004
Full case nameJose Francisco Sosa v. Humberto Alvarez-Machain, et al.
Docket no.03-339
Citations542 U.S. 692 (more)
124 S. Ct. 2739; 159 L. Ed. 2d 718; 2004 U.S. LEXIS 4763; 72 U.S.L.W. 4660; 158 Oil & Gas Rep. 601; 2004 Fla. L. Weekly Fed. S 515
ArgumentOral argument
Case history
PriorOn writ of certiorari to the U.S. Court of Appeal for the Ninth Circuit.
Holding
The Federal Tort Claims Act's exception to waiver of sovereign immunity for claims "arising in a foreign country" bars claims based on any injury suffered in a foreign country, regardless of where the tortious act or omission occurred.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajoritySouter, joined by unanimous (Parts I and III); Rehnquist, Stevens, O'Connor, Scalia, Kennedy, Thomas (Part II); Stevens, O'Connor, Kennedy, Ginsburg, Breyer (Part IV)
ConcurrenceScalia (in part), joined by Rehnquist, Thomas
ConcurrenceGinsburg (in part), joined by Breyer
ConcurrenceBreyer (in part)
Laws applied
Alien Tort Statute

Sosa v. Alvarez-Machain, 542 U.S. 692 (2004), was a United States Supreme Court case involving the Alien Tort Statute and the Federal Tort Claims Act. Many ATS claims were filed after the Second Circuit ruling in Filártiga v. Peña-Irala created a new common law cause of action for torture under the ATS: "For purposes of civil liability, the torturer has become—like the pirate and slave trader before him—hostis humani generis, an enemy of all mankind." The Court in Sosa does not find there is a similar cause of action for arbitrary arrest and detention. They wrote that finding new common law causes of action based on international norms would require "a substantial element of discretionary judgment", and explain that the role of common law has changed since ATS was enacted meaning the Court will "look for legislative guidance before exercising innovative authority over substantive law".

The decision states some limitations on recognizing (or creating) new federal common law causes of action under the ATS: "norms of international character accepted by the civilized world and defined with a specificity comparable to the features of those three 18th century paradigms we have recognized".