The U.S. Supreme Court's decision in Kiobel v. Royal Dutch Petroleum Co. has ushered in a new era for human rights enforcement. Unanimously, the Court ended so–called foreigncubed human rights cases, that is, litigation where foreign plaintiffs sue foreign defendants for activity occurring abroad. The broadest form of universal civil jurisdiction that the Second Circuit's decision in Filártiga v.Pena–Irala once appeared to promise is over. Alien Tort Statute (ATS) litigation, while not foreclosed, has become more limited.