More and more sovereign entities will face tort litigation in the foreseeable future because they are involved in businesses through direct or indirect owenership. A wrinkle on that general issue is whether and when the Holy See, a/k/a The Vatican , can be sued. The issues are complex because it is a nation state. Recent case law in the area is summarized in an interesting article by Russell Jackson of Skadden Arps. He also hosts a blog at www.consumerclassactionsmasstorts.com. The case law he discusses includes Doe v. Holy See, 557 F.3d 1066 (9th Cir. 2009), and O’Brien v. Holy See, 556 F.3d 361 (6th Cir. 2009). The article is here.