On April 20, 2015, the Supreme Court of the United States (the Court) denied certiorari [3] in Cardona v. Chiquita Brands International, Inc., a case in which the relatives of the victims of Colombia’s paramilitary violence sued Chiquita Brands International, Inc. for funding paramilitaries. The plaintiffs petitioned the Court after the U.S. Court of Appeals for the Eleventh Circuit, quoting Kiobel v. Royal Dutch Petroleum [4], dismissed the case [5] in 2014 on the ground that it lacked jurisdiction to hear a “case seeking relief for violations of the law of nations occurring outside the United States.” The suit, which was filed under the Alien Tort Statute [6] and the Torture Victims Protection Act [7], alleged claims involving torture, personal injury, and death.