In "Doe v. Qi", the court stated, "The fact that there may be doubt at the marginsa fact that inheres in any definitiondoes not negate the essence and application of that definition in clear cases." The court also described how to determine whether specific actions fall within the proscriptions of an international norm, holding that the actions alleged should be compared with actions that international adjudicatory bodies have found to be proscribed by the norm in question. It therefore examined decisions by institutions such as the Human Rights Committee, the European Court of Human Rights, and the African Commission on Human and Peoples' Rights to determine that pushing, hitting, and choking a plaintiff during one day of incarceration did not constitute cruel, unusual, or degrading treatment, whereas forcing a hand into a plaintiff's vagina did constitute cruel, inhuman, or degrading treatment. As of October 2011, there was a circuit split regarding whether corporations, as opposed to natural people, could be held liable under the ATS. In 2010 the Second Circuit Court of Appeals held in "Kiobel v. Royal Dutch Petroleum Co." that "customary international law has steadfastly rejected the notion of corporate liability for international crimes" and thus that "insofar as plaintiffs bring claims under the ATS against corporations, plaintiffs fail to allege violations of the law of nations, and plaintiffs' claims fall outside the limited jurisdiction provided by the ATS". However, in 2011, the Seventh Circuit Court of Appeals, the Ninth Circuit Court of Appeals, and the D.C. Circuit Court of Appeals all ruled that corporate liability is possible under the statute. The U.S. Supreme Court granted certiori on October 17, 2011, to answer the question of corporate liability. After arguments on February 28, 2012, the Court ordered the case to be reargued the following term on the separate question of extraterritoriality. On April 17, 2013, in "Kiobel v. Royal Dutch Petroleum Co.", the U.S. Supreme Court issued a decision affirming the Second Circuit Court of Appeals but on different grounds, holding that the ATS did not create jurisdiction for a claim regarding conduct occurring outside the territory of the United States, leaving the question of corporate liability unresolved. In "Jesner v. Arab Bank, PLC", the Supreme Court again revisited the question of corporate liability and ruled that foreign corporations may not be sued under the ATS. However, the only parts of the opinion that commanded a majority of the court expressly limited its holding to suits against foreign corporations.