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.

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