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20 Minn. J. Int'l L. 144 (2011)
Presbyterian Church of Sudan v. Talisman Energy, Inc.: Aiding and Abetting Liability under the Alien Tort Statute

handle is hein.journals/mjgt20 and id is 146 raw text is: Note Presbyterian Church of Sudan v. Talisman Energy, Inc.: Aiding and Abetting Liability Under the Alien Tort Statute James Morrissey I. INTRODUCTION In 2001, the Presbyterian Church of Sudan and several individuals filed suit in United States Federal Court against Talisman Energy, Inc. (Talisman).' The plaintiffs alleged that Talisman was complicit in the Sudanese government's human rights abuses against largely non-Muslim Sudanese civilians living in the area of the company's oil concession.2 The plaintiffs alleged that the Sudanese government orchestrated an armed campaign of murder, rape and massive civilian displacement in order to clear the way for oil exploration.3 On October 2, 2009, the U.S. Court of Appeals for the Second Circuit issued its opinion in Presbyterian Church of Sudan v. Talisman Energy, Inc.4 Upholding the lower court's ruling of summary judgment in favor of defendant Talisman, the Second Circuit set a high bar for plaintiffs who seek to use the Alien Tort Statute (ATS) to 1. Presbyterian Church of Sudan v. Talisman Energy, Inc., 582 F.3d 244, 251 (2d Cir. 2009). 2. See id. at 248-51 (noting that civilians represented by plaintiff were living in areas of land proximate to Talisman's oil concession). 3. See David Glovin, Talisman Court Upholds Genocide Suit Dismissal, BLOOMBERG (Oct. 2, 2009, 14:20EDT), http://www.bloomberg.com/apps/news?pid=20601082&sid=av47UyrplgEQ (linking defendants' alleged human rights violations to oil exploration); BUSINESS & HUMAN RIGHTS RESOURCE CENTRE, Case Profile: Talisman Lawsuit (re Sudan), http://www.business- humanrights.org/Categories/Lawlawsuits/LLawsuitsregulatoryactio/LawsuitsSelecte dcLaws/TalismanlawsuitreSudan (last visited Jan. 12, 2010) (listing alleged human rights violations of Talisman). 4. Talisman, 582 F.3d at 244. 144

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