International
ATS claim barred under the presumption against extraterritorial application, as it does not extensively and directly touch and concern the USA.
Foreign officials cannot claim sovereign immunity in TVPA actions alleging jus cogens violations.
Concur/Dissent: Deft is non-adventitiously a lawful permanent resident who earlier did military training in the USA, so ATS allows the claim.
http://www.ca4.uscourts.gov/Opinions/Published/141810.P.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.