St. John's Law Review Volume 67 Number 3 Volume 67, Summer 1993, Number 3 Article 3 April 2012 The Future of the Alien Tort Claims Act of 1789: Lessons from In re Marcos Human Rights Litigation Joan Fitzpatrick Follow this and additional works at: https://scholarship.law.stjohns.edu/lawreview Recommended Citation Fitzpatrick, Joan (1993) "The Future of the Alien Tort Claims Act of 1789: Lessons from In re Marcos Human Rights Litigation," St. John's Law Review: Vol. 67 : No. 3 , Article 3. Available at: https://scholarship.law.stjohns.edu/lawreview/vol67/iss3/3 This Symposium is brought to you for free and open access by the Journals at St. John's Law Scholarship Repository. It has been accepted for inclusion in St. John's Law Review by an authorized editor of St. John's Law Scholarship Repository. For more information, please contact
[email protected]. THE FUTURE OF THE ALIEN TORT CLAIMS ACT OF 1789: LESSONS FROM IN RE MARCOS HUMAN RIGHTS LITIGATION JOAN FTZPATRCK* INTRODUCTION On September 24, 1992, a federal civil jury in Honolulu ren- dered a verdict for the plaintiffs in the multidistrict human rights litigation against the estate of Ferdinand Marcos and several of his former associates and family members.' In re Marcos Human Rights Litigation ("Marcos") is a milestone for the Alien Tort Claims Act ("ATCA7)2 for several reasons. First, Marcos was the first human rights case brought under the ATCA to be fully con- tested in a trial on the merits, illustrating the numerous obstacles that plaintiffs must overcome in proving human rights allega- tions.