The Supreme Court’s order requesting supplemental briefing in Kiobel v. Royal Dutch Petroleum posed two intertwined questions. The Court asked first “whether” the Alien Tort Statute (“ATS”) “allows courts to recognize a cause of action” for international law violations occurring within the territory of a foreign sovereign. The answer to that question is clearly “yes.”…The Court also asked “under what circumstances” the ATS “allows courts to recognize a cause of action” for extraterritorial violations. The answer to this second question will inevitably be complicated by importing a myriad of irrelevant “circumstances”…into what is also a straightforward question. In Sosa v. Alvarez-Machain, the Court explained the circumstances in which the ATS allows courts to recognize a cause of action for violations of the law of nations: when a plaintiff makes plausible allegations of tortious conduct that violates a clearly defined, widely accepted norm of international law.