appellants argued that Peña's actions had violated wrongful death statutes, the United Nations Charter, the Universal Declaration of Human Rights, the American Declaration of the Rights and Duties of Man, and other customary international law. They also claimed the U.S. courts had jurisdiction to hear the case under the Alien Tort Statute, which grants district courts original jurisdiction to hear tort claims brought by an alien that have been "committed in violation of the law of nations or a treaty of the United States". This case interpreted that statute to grant jurisdiction over claims for torts committed both within the United States and abroad. Judgment U.S. courts eventually ruled in favor of the Filártigas, awarding them roughly $10.4 million. Torture was clearly a violation of the law of nations, and the United States did have jurisdiction over the case since the claim was lodged when both parties were inside the United States. Additionally, Peña had sought to dismiss the case based on forum non conveniens, arguing that Paraguay was a more convenient location for the trial, but he did not succeed. Subsequent events Following the judgment in Filártiga, there was a concern that the U.S. would evolve into a haven for international tort claims. In Kadic v Karadžić (1995), victims of atrocities committed in Bosnia during the Bosnian War commenced proceedings against Serbia for war crimes in an American domestic court, with Radovan Karadžić being in the U.S. at the time. The United States Court of Appeals for the Second Circuit then considered issues as to the scope of ATS claims, specifically concerning non-state actors as defendants and the related question of whether genocide, war crimes and crimes against humanity require a state action. The Court of Appeals found that federal courts have subject matter jurisdiction under ATS even where defendants were not acting under "color of state law", when the allegations touched upon genocide, summary executions, torture and war crimes. Following the Karadžić judgment, it was ruled in Sosa v. Alvarez-Machain 542 U.S. 692 (2004) that Congress intended with the Alien Tort Statute that extraterritorial jurisdiction was allowed for only the most egregious international crimes. This was further limited in Kiobel v. Royal Dutch Petroleum Co., where it was affirmed that there was a presumption against extraterritoriality and that "mere corporate presence" in the United States was not enough to overcome that presumption in cases where all the alleged