The reach of the Iqbal decision continues to spread

Law.com reported yesterday that "In a 34-page ruling (pdf) that one defense lawyer describes as "a sweeping review of the Alien Tort Statute," a three-judge panel of the 11th U.S. Circuit Court of Appeals upheld a Miami federal district court's dismissal of four cases claiming that Coca-Cola and its two Colombian bottling subsidiaries were liable for the murder and torture of trade unionists by Colombian paramilitary forces. Citing the Supreme Court's now-infamous May 2009 ruling in Ashcroft v. Iqbal (pdf), the court concluded that the plaintiffs' complaints "fail to sufficiently plead factual allegations" to establish subject matter jurisdiction and state a valid claim." For the rest of the story go here.