In 2010 a sharply divided 2nd Circuit Court of Appeals dismissed Kiobel, agreeing that the law did not apply to companies.

ECONOMIST: A review of extreme extraterritoriality

The District Court granted the petition, and a divided panel of the First Circuit affirmed.

FORBES: Protecting Tax Accrual Workpapers from IRS Summons

In a divided opinion, the Sixth Circuit held that it did.

CENTERFORSECURITYPOLICY: Center For Security Policy

The questions of how and when an agency may exempt itself from the Privacy Act are not only central to this case, but also have divided the federal courts of appeals into two camps, a circuit split that could be resolved by the U.S. Supreme Court should Shearson petition successfully for her case to be heard.

FORBES: Should Government Agencies Be Able To Exempt Themselves From The Privacy Act?