Chief Justice Roberts won. In Kiobel v. Royal Dutch Petroleum, he took an issue so hot that 82 amicus groups weighed in, and rendered a ruling so tepid that the story ran on page A22 of The New York Times. Had the U.S. Supreme Court barred human rights liability for corporations, a snarky front-pager might have noted the contrast to Citizens United: A corporation has the right to buy elections because it's a person, yet may commit genocide with impunity because it's not a person. But that's not what happened. Rather than kill the corporate alien tort outright, the Court maimed all forms of alien tort by restricting their territorial reach. The corporate alien tort is therefore doomed to remain a zombie doctrine--not quite alive and not quite dead.