Al-Khalifa v. Trayers
The Alien Tort Statute, 28 United States Code §1350, does not confer jurisdiction over conduct that takes place outside the United States. The pro se plaintiff, Oluwashina Ahmed-Al-Khalifa, sued the defendants, alleging that they provided ineffective assistance of counsel in a deportation matter, and the plaintiff was deported to Nigeria. The plaintiff requested compensation of $1.6 billion European Euros and $500 million pounds. The Alien Tort Statute provides jurisdiction over "any civil action by an alien for a tort only, committed in violation of the law of nations or a treaty of the United States." In a 2013 decision, Kiobel v. Royal Dutch Petroleum Co., the U.S. Supreme Court held that the Alien Tort Statute does not apply "to conduct in the territory of another sovereign." Here, the plaintiff's allegations that defendants in foreign countries provided ineffective assistance of counsel to the plaintiff are insufficient to provide the Connecticut District Court with jurisdiction. The court dismissed the plaintiff's complaint.