Lawyers really embraced the 1789 law after the U.S. Supreme Court decided in 2004 that a Mexican national could not use the ATS to sue the Mexican agent who abductedhim on instructions of U.S. officials.
Separately, the European Court of Human Rights recently held that the government of Macedonia violated the rights of Khaled El-Masri, a German national who alleged the CIA abductedhim from Macedonia and sent him for interrogation in Afghanistan as part of a terrorism investigation.