On April 16, 2009, the U.S. Court of Appeals for the Second Circuit issued a decision that reined in activists’ use of the Alien Tort Statute (ATS) as a means of attempting to enforce international human rights law in federal courts. The court held that a former Israeli cabinet officer, who was sued by Palestinians for military actions taken actions in the Gaza Strip, was entitled to immunity from suit under the ATS. The decision was a victory for WLF, which filed a brief urging the appeals court to dismiss the suit. WLF argued that when it adopted the ATS in 1789, Congress never intended to assign federal courts the role of policing alleged human rights violations throughout the world. The appeals court agreed with WLF that immunity from such suits is not limited to foreign governments and their current leaders. Rather, the court held, former leaders are also entitled to common law immunity — at least when, as here, the U.S. government submits a statement supporting the immunity