Generally, the U.S. founding fathers and early courts believed that American laws could not have jurisdiction over sovereign countries. In a 1909 Supreme Court case, Justice Oliver Wendel Holmes introduced what came to be known as the "presumption against extraterritoriality," making explicit this judicial preference that U.S. laws not be applied to other countries. American thought about extraterritoriality has changed over the years, however. For example, the Alien Tort Statute of 1789 allows foreign citizens in the United States to bring cases before federal courts against foreign defendants for violations of the "law of nations" in foreign countries. Although this statute was ignored for many years, U.S. courts since the 1980s have interpreted it to allow foreigners to seek justice in cases of human-rights violations in foreign lands, such as in "Sosa v. Alvarez-Machain". In "Morrison v. National Australia Bank," 2010, the Supreme Court held that in interpreting a statute, the "presumption against extraterritoriality" is absolute unless the text of the statute explicitly says otherwise.