Cited in:  Jeffrey A. Van Detta, Some Legal Considerations For E.U.-Based MNEs Contemplating High-Risk Foreign Direct Investments in the Energy Sector After Kiobel v. Royal Dutch Petroleum and Chevron Corporation v. Naranjo, 9 S.C. J. Int'l L. & Bus. 161, 241 (Spring 2013). 

The article is cited for: 

(arguing that the House emendation of "foreigner" from the Senate Bill to "alien" in the Judiciary Act as passed evidences an even further narrowing of the scope of the ATS to apply: "Considering Article III of the Constitution and the related provisions in the Judiciary Act of 1789, along with the late eighteenth century legal, international, and general uses and definitions of "alien" and "foreigner"-in conjunction with relevant changes that occurred from the Senate's handwritten draft of the judicial bill through subsequent codifications of relevant sections of the Judiciary Act of 1789-it is fair to say that an understanding of what Congress intended by the deceptively simple change from "foreigner" to "alien" was a narrowing of the ATS; making it available to "aliens" but not to "foreigners," . . . in other words, making it available only to residents of the United States.").