Full opinion text
OPINION AND ORDER NORGLE, District Judge. Before the court is Defendants’ Joint Motion to Dismiss. For the following reasons, the motion is granted. I. INTRODUCTION This case arises out of the institution of human chattel slavery as it existed in the North American colonies and the latter-formed United States of America. The allegations in Plaintiffs’ First Amended and Consolidated Complaint (“FACC” or “Complaint”) retell the generally acknowledged horrors of the institution of slavery, and the malignant actions of the sovereigns, entities and individuals that supported that institution. Plaintiffs’ Complaint asks the courts to reexamine a tragic period in our Nation’s history and to hold various corporate defendants liable for the commercial activities of their alleged predecessors before, during and after the Civil War in America. Defendants acknowledge that slavery marked a deplorable period in our Nation’s history. However, they assert that Plaintiffs’ claims, which arise from that period, cannot be heard in 2004 in a court of law. II. HISTORICAL OVERVIEW OF SLAVERY IN AMERICA In essence, Plaintiffs’ Complaint is a claim for reparations rooted in the historic injustices and the immorality of the institution of human chattel slavery in the United States. To elucidate the nature of this institution, the court undertakes an analysis, necessarily brief, of the historical events surrounding slavery, including the monumental event that ended the institution of slavery in the United States, the Civil War. A. A Definition of Slavery In January of 1865, General William Tecumseh Sherman of the Union forces, along with Secretary of War Edwin Stanton, met with former slaves. Ira Berlin, Generations of Captivity: A History of African-American Slaves 2 (2003). The conversation focused on two questions: from the point of view of the freed slave, what was the nature of slavery, and what was the nature of freedom? Id. Garrison Frazier, a sixty-seven year old former slave, explained that “[sjlavery ... is receiving by the irresistible power the work of another man, and not by his consent.” Id. Freedom, Frazier indicated, “is taking us from the yoke of bondage, and placing us where we could reap the fruits of our own labor, take care of ourselves and assist the Government in maintaining our freedom.” Id. Frazier’s definition reminds us of the essential unfairness of slavery: the slaveowner takes, by sheer violence and force, the slave’s freedom and labor in order to place himself at the top of a society’s economic hierarchy. Id. at 3. B. A Brief History of Slavery in the New World While slavery seems to have been a part of human history since the “dawn of civilization,” African slave trafficking in the New World began in the year 1502. Robert William Fogel, Without Consent or Contract: The Rise and Fall of American Slavery 17-18 (1991). Europeans were historically drawn to Africa for two reasons: gold and slaves. Edward Reynolds, Stand the Storm. A History of the Atlantic Slave Trade 28 (1985). Those who journeyed to Africa seeking slaves for the New World sometimes simply kidnapped individuals who appeared before them by happenstance. Herbert S. Klein, The Atlantic Slave Trade 103 (1999). However, historical evidence indicates that a great deal (perhaps even the majority) of the slave trade was made possible by African leaders who sold African slaves to European slave traders. Id.; see also Reynolds, supra at 33-46 (providing a detailed explanation of the African slave market, and the economic mechanisms used to facilitate the sale of slaves from local African chiefs to slave traders). Local African leaders acquired these slaves in several different ways: captives were taken in local wars or raids, those imprisoned for crimes or indebtedness were often forced into slavery, and large states would exact slaves as “tribute” from smaller tribes under their control. See Klein, supra at 117. Upon their sale to slave traders, slaves were shipped to the New World in what became known as the “Middle Passage.” Slaves’ heads were shaved, their bodies were branded and stripped naked, and their ankles were shackled. See Reynolds, supra at 47. They were then led into the holds of slave ships, where they were laid down alongside each other for the journey to the New World. Id. at 48. The prevalence of disease, lack of sufficient food and water, and constant confinement took its toll, with up to one-quarter of the slaves on any given ship dying during the “Middle Passage.” Id. at 48-53. African slaves in the New World were initially sold into small sugar production operations in Brazil, Mexico, Peru, Cuba, Haiti, Jamaica, the British West Indies, and Dutch Guyana. Id. at 20-21. Other African slaves were set to work producing such crops as cocoa, coffee, hemp, tobacco and rice. Id. at 21. By the 1680s, the small farm with its traditional methods of operation had given way to more efficient means of production, and the concept of the large “plantation” was born. Id. at 23. Inefficient methods of farming had been “replaced by large gangs of slaves, working in lock step, and moving methodically across vast fields.” Id. With this change came an increase in the size of slave operations. By the early part of the 1800s, many plantations in Jamaica and the West Indies contained up to two hundred and fifty slaves. Id. Slavery in North America began more slowly than slavery in South America and the Caribbean. In 1680, there were 7,000 slaves in the British North American colonies. Id. at 29. Slavery as an economic institution in North America, however, rapidly gained momentum over the next fifty years. By the 1730s, roughly 120,000 slaves had been brought to the colonies and forced to work in such industries as farming, tobacco production and domestic service. Id. By the middle of the 1700s, the institution of slavery in the United States began to concentrate in the Southern states. It was in these states that plantations emerged, ready to take advantage of the inexpensive labor slaves provided in the production of such crops as tobacco, rice, sugar and cotton. Id. at 31. During the years 1780 to 1810, the rapid expansion of these industries was accompanied by a significant increase in the number of slaves imported from Africa. Id. at 32. The increase in the importation of slaves, along with the natural increase in the slave population, soon gave the United States a dubious distinction. By 1825, the population of slaves in the United States was roughly 1,750,000, making the United States the “leading user of slave labor in the new world.” Id. at 33. Slavery had become the dominant economic force in the Southern United States. Historians cite numerous factors for this development, but it seems that two factors are the most significant. First, slave labor was inexpensive compared to other sources of labor. Id. at 34. Second, slave masters in the Southern states were willing to expend an “enormous, almost unconstrained degree of force ... to transform ancient modes of labor into a new industrial discipline.” Id. This “new industrial discipline” was based on a division of labor scheme; enforced by brutality, and legally sanctioned. C. Slavery and American Law This violent and oppressive system was supported by the United States legal system for a long period of time. Thus slavery was historically more than simply a social and economic institution. It was also an established legal institution. For instance, Article I, Section 9 of the United States Constitution has been traditionally understood to limit Congress’ power to regulate slavery. It is thought that this Article meant that Congress was denied the power to regulate the “internal slave trade, leaving only importation from .Africa to be prohibited after 1808.” Walter Berns, The Constitution and the Migration of Slaves, 78 Yale L.J. 198 , (1968). Also, in 1850, Congress passed a statute supporting the rights of slaveowners to capture escaped slaves. The Fugitive Slave Act provided that: [W]hen a person held to service or labor in any State or Territory of the United States, has heretofore or shall hereafter escape into another State or Territory of the United States, the person or persons to whom such labor or service shall be due ... may pursue and reclaim such fugitive person ... [and may] take and remove such fugitive person back to the State or Territory whence he or she may have escaped as aforesaid. The Fugitive Slave Act, eh. 60, 9 Stat. 462 (1850). This Act also provided for fines and/or imprisonment for those who aided escaped slaves, and stipulated that both law enforcement personnel and ordinary citizens were bound by law to aid in the capture of escaped slaves. Id. Finally, in the infamous case of Dred Scott v. Sandford, Scott, a slave, brought suit to gain his freedom. 60 U.S. 393, 19 How. 393, 15 L.Ed. 691 (1856). The Supreme Court of the United States held that since Scott was a “negro, whose ancestors were imported into this country, and sold as slaves,” he could not be a citizen of the United States, and hence had no standing to bring suit in a United States court. Id. at 403-04, 19 How. 393. D. Slavery and Morality The immorality of the institution of slavery is obvious. However, scholars have attempted to explain exactly what it is about this institution that offends moral sensibilities. Two moral indictments of the institution are significant. First, “slavery permitted one group of people to exercise unrestrained personal domination over another group of people.” Fogel, supra at 394. The slave was subject to abject cruelty, both physical and psychological, by his or her masters in order for the master to maintain domination. Id. In one sense, “[t]he extreme degree of domination required by this system ... is the essential crime.” Id. Second, the slave was denied the fruits of his or her labor. Id. at 395. Slaves were forced to work physically grueling tasks for very long hours without pay, thus it was impossible for the slave to improve his or her economic position within society. Id. The simply had no resources or “opportunity ... to rise on the economic ladder by acquiring land, labor skills, and other forms of capital.” Id. E. Slavery as a Cause of the Civil War Historians have long debated whether slavery was the single driving force behind the regional tensions in the United States that eventually led to the Civil War. “Although some scholars have held that slavery was the cause [of the Civil War], others have developed complex analyses that draw distinctions between immediate and ultimate causes and that explore a variety of ways other than war that could have settled or at least contained the issue of slavery.” Id. at 411. This much, however, is clear: by 1861, tensions had escalated to the extent that maintaining peace would have required that the Northern states allow the permanent “existence of an independent confederacy dedicated to the promotion of slavery.” Id. at 413. In other words, by 1861, tensions between the North and the South had increased to such a pitch that the only way slavery would be abolished throughout the entire nation was through armed conflict. A great deal of the tension between the North and the South had to do with the Northern states’ promulgation of Personal Liberty Laws. “In his annual message to Congress of December 3, 1860, James Buchanan warned that the South ‘would be justified in revolutionary resistance to the Government of the Union’ if northern states did not repeal their Personal Liberty Laws.” Thomas D. Morris, Free Men All: The Personal Liberty Laws of the North 1780-1861 202 (1974). These laws were devised ■ and implemented by many Northern states to make it very difficult for slave owners to capture escaped slaves who had taken up residence in those states. The court does not claim objective knowledge of the ultimate cause of the Civil War. Certainly, however, tensions marked by the North’s moral outrage at the institution of chattel slavery, and the South’s indignation at the North’s promulgation of Personal Liberty Laws, contributed significantly to the advent of war. F. The Civil War : Fort Sumter, located in the Charleston harbor, South Carolina, was one of just four Federal fortifications left in Confederate territory. Shelby Foote, The Civil War, A Narrative: Fort Sumter to Perry-ville 44 (Vintage Books 1986) (1958). In 1861, the government of South Carolina made protests to Washington regarding the presence of a Federal fortification within its borders, but those protests were ignored. Id. Instead, Washington decided to reinforce Fort Sumter with men and supplies. Id. However, when local gunmen opened fire on a Union steamer attempting to bring these reinforcements to Fort Sumter, the steamer was forced to turn away. Id. By March of 1861, Fort Sumter was surrounded by Confederate forces, and was cut off from fresh supplies. Id. By April of that year, the Federal forces inside Fort Sumter were in danger of starving to death. Id. at 48. The time had come for Washington to make a decision-abandon Fort Sumter or again attempt to resupply it. Washington was aware that another attempt to bring supplies to Fort Sumter might well provoke an attack on the forth itself. Id. at 47. This time, however, the attack would not come from local gunmen, but from Confederate forces. Id. Washington decided not to cave in to Confederate pressures, and to attempt to bring fresh provisions and rein: forcements to the fort. Id. at 47. On the morning of April 12, 1861, with Union supply ships within sight of Fort Sumter, the Confederacy fired the first shot of the Civil War. Id. at 49. The four-year Civil War was fought by means of a series of pitched battles, each one seemingly more horrific than the last. The first true battle of the war, the battle of Bull Run, resulted in the deaths of roughly 2,700 Union soldiers and 2,000 Confederate soldiers. The Price in Blood, Casualties in the Civil War, at http:// www.civilwarhome.com/casualties.htm. Other battles, at places like Wilson’s Creek, Spotslyvania, Cold Harbor, and Franklin, Tennessee took the lives of tens of thousands of Union and Confederate soldiers. Id. The final campaign of the war, fought in the vicinity of Appomattox, Virginia, resulted in a combined 17,500 battle deaths. Id. Following the Appomattox campaign, on April 9, 1865, Union General Ulysses S. Grant received Confederate General Robert E. Lee at Appomattox Courthouse, where the two generals agreed upon the terms of Lee’s surrender. Shelby Foote, The Civil War, A Narrative: Red River to Appomattox 945-51 (Vintage Books 1986) (1974). Shortly thereafter, Grant rode out towards his headquarters, where Union batteries were firing in celebration. Id. at 950-51. Grant insisted the batteries stop firing, worried that the noise might spark a skirmish between his troops and the nearby, and still armed, Confederate soldiers. Id. at 951. There was, however, another more important reason Grant considered it “unfitting” for his troops to be firing their weapons at that point: “ ‘The war is over,’ he told his staff. ‘The rebels are our countrymen again.’ ” Id. All in all, approximately 620,000 Americans died in the Civil War; Union forces fighting to end slavery suffered 360,000 of these deaths. James M. McPherson, Battle Cry of Freedom: The Civil War Era 854 (Oxford University Press 1988). There were 178,975 African-American Union troops that fought in the Civil War, and 36,000 of those troops died during the war. The Price in Blood, Casualties in the Civil War, at http://www.civilwar-home.com/casualties.htm. An analysis as brief as this cannot do justice to the tremendous sacrifices made by both Union and Confederate soldiers in this war. Since the Civil War, America has been involved in a number of armed conflicts, but the casualties America suffered in the Civil War exceeds the total number of casualties America has suffered in all its other wars.' Id. The Civil War, the war that ended the institution of chattel slavery in the United States, was truly America’s bloodiest war. G. The Abolishment of Slavery On January 1, 1863, in the midst of the Civil War, President Abraham Lincoln issued the Emancipation Proclamation. That document reads in part: “I do order and declare that all persons held as slaves within the designated States ... are, and henceforward shall be free.... ” Abraham Lincoln, The' Emancipation Proclamation, Exec. Proclamation No. 17 (Jan. 1, 1863), reprinted in 12 Stat. 1268 (1963). Following the war, Congress acted to formally abolish slavery by proposing the Thirteenth Amendment to the United States Constitution. That Amendment was ratifiéd on December 6, 1865. Section 1 of that Amendment reads: “Neither slavery nor involuntary servitude, except as punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction.” U.S. Const, amend. XIII, § 1. Also, the Fourteenth Amendment to the United States Constitution was ratified on July 9, 1868. Section 1 of that Amendment reads: “All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State in which they reside.” U.S. Const, amend. XIV, § 1. In effect, the Fourteenth Amendment overruled the Dred Scott decision, making freed slaves citizens of the United States. Following the Civil War, the South was bankrupt, and an estimated four million African-Americans assumed the responsibility of freedom as nationalism emerged. These lingering effects led to the Reconstruction era, a significant period in our Nation’s history, which addressed the numerous issues raised by the abolition of slavery and the war fought to achieve that end. III. OVERVIEW OF THE PROCEEDINGS A. Parties 1. Plaintiffs Beginning in 2002, a number of lawsuits were filed by descendants of slaves seeking reparations from private corporations, which were alleged to have unjustly profited from the institution of slavery. On October 25, 2002, the Judicial Panel on Multidistrict Litigation transferred these actions to this court for coordinated or consolidated pretrial proceedings pursuant to 28 U.S.C. § 1407. See In re African-American Slave Descendants Litigation, No. 1491, 231 F.Supp.2d 1357 (Jud.Pan.Mult.Lit., Oct.25, 2002). This litigation presently consists of nine individual lawsuits, and these individual plaintiffs have filed a consolidated complaint. See Pis.’ First Amended Consolidated Complaint. The plaintiffs in these cases include the following: Deadria Farmer-Paellmann, Mary Lacey Madison, Andre Carrington, Richard Barber, Sr., Hannah Jane Hurdle-Toomey, Marcelle Besteda Porter, Julie Mae Wyatt-Kervin, Emma Marie Clark, Ina Bell Daniels Hurdle McGee, C. Doe, Antoinette Harrell Miller, as well as a group of seven anonymous plaintiffs. The named plaintiffs (hereinafter collectively referred to as “Plaintiffs”), on behalf of themselves and the classes they seek to represent, seek reparations on behalf of all “descendants of formerly enslaved Africans” and all living “formerly enslaved African-Americans.” See FACC ¶ 60. Specifically, Plaintiffs seek an accounting, constructive trust, restitution, disgorgement, compensatory and punitive damages arising out of the named defendants’ alleged past and continued wrongful conduct relating to the institution of slavery. See id. ¶ 55. 2. Defendants The named defendants (hereinafter collectively referred to as “Defendants”) are eighteen present-day companies whose predecessors are alleged to have been unjustly enriched through profits earned either directly or indirectly from the TransAtlantic Slave Trade and slavery between 1619 and 1865, as well as post-Emancipation slavery through the 1960s. Defendants include the following companies: FleetBoston Financial Corporation, CSX Corporation, Aetna Inc., Brown Brothers Harriman, New York Life Insurance Company, Norfolk Southern Corporation, Lehman Brothers, Lloyd’s of London, Union Pacific Railroad, JP Morgan Chase Manhattan Bank, Westpoint Stevens Inc., RJ Reynolds Tobacco Company, Brown and Williamson, Liggett Group Inc., Loews Corporation, Canadian National Railway, Southern Mutual Insurance Company, and American International Group (“AIG”). Plaintiffs allege that FleetBoston, through its predecessor bank, made loans to slave traders and also collected custom duties and fees on ships engaged in the slave trade. See id. ¶¶ 125-27. Plaintiffs further allege that “FleetBoston engaged in a self-concealed business enterprise so that the plaintiff class and/or plaintiffs’ ancestors would not be aware of the existence of this enterprise,” and, in more recent times, “made various misleading statements to the Press from March 2000 to February 2002, attempting to disassociate its predecessor company from its current company.” Id. ¶¶ 129-30. Plaintiffs allege that CSX “is a successor-in-interest to numerous predecessor railroad lines that were constructed or run, at least in part, by slave labor.” Id. ¶ 131. Plaintiffs further allege that “CSX engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise,” and, in more recent times, “withheld information or made a misleading statement to the Press regarding their participation in and profiting from slavery.” Id. ¶¶ 132-33. Plaintiffs allege that “Aetna’s predecessors in interest, actually insured slave owners against the loss of their human chattel ... [and] therefore unjustly profited from the institution of slavery.” Id. ¶ 134. Plaintiffs further allege that “Aetna engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise,” and, in more recent times, “withheld information or made a misleading statement regarding their participation in and profiting from slavery.” Id. ¶¶ 135-36. Plaintiffs allege that Brown Brothers Harriman is the successor corporation to Brown Brothers & Co., which “loaned millions directly to planters, merchants and cotton brokers throughout the South, ... [and] records also reveal that Brown Brothers loaned to plantation owners who told the firm that they needed the cash to buy slaves.” Id. ¶ 137. Plaintiffs also allege that “Louisiana court records dating back to the 1840’s ... reveal the firm’s ownership of at least two cotton plantations totaling 4,614 acres and the plantations’ 346 slaves.” Id. ¶ 138. Plaintiffs further allege that “Brown Brothers Har-riman engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise,” and, in more recent times, “withheld information or made a misleading statement based on press reports after the filing, trying to disassociate ... from its predecessor’s business.” Id. ¶¶ 140-41. Plaintiffs allege that “New York Life’s predecessor-in-interest, Nautilus Insurance, earned premiums from its sale of life insurance to slave owners.” Id. ¶ 142. Plaintiffs further allege that “New York Life engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise,” and, in more recent times, “withheld information or made misleading statements regarding their participation in and profiting from slavery.” Id. ¶¶ 143,145. Plaintiffs allege that Norfolk Southern “is a successor-in-interest to numerous railroad lines that were constructed or run, in part, by slave labor.” Id. ¶ 147. Plaintiffs allege that the founder of Lehman Brothers, Henry Lehman, and his brothers “grew rich as middlemen in the slave-grown cotton trade.” Id. ¶ 148. Plaintiffs allege that Lloyd’s of London “was involved in the insuring of ships utilized for the Trans-Atlantic slave trade.” Id. ¶ 149. Plaintiffs further allege that “Lloyd’s engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise.” Id. ¶ 150. Plaintiffs allege that Union Pacific “is a successor-in-interest to numerous predecessor railroad lines that were constructed or run in part by slave labor.” Id. ¶ 152. Plaintiffs further allege that “Union Pacific engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise,” and, in more recent times, “withheld information or made a misleading statement regarding their participation in profiting from slavery.” Id. ¶¶ 153-54. Plaintiffs allege that two of the predecessor banks that merged to create J.P. Morgan Chase “were behind a consortium to raise money to insure slavery.” Id. ¶ 155. Plaintiffs further allege that “J.P. Morgan Chase engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise,” and, in more recent times, “withheld information or made a misleading statement regarding their participation in and profiting from slavery.” Id. ¶¶ 156-57. Plaintiffs allege that Westpoint Stevens “is a successor-in-interest to Pepperell Manufacturing which utilized cotton from Southern planters farmed by enslaved Africans.” Id. ¶ 160. Plaintiffs allege that R.J. Reynolds Tobacco Company, Brown & Williamson, Lig-gett Group and Lowes Corporation (parent company of Lorillard Tobacco Company), which were all once part of the American Tobacco Company, are the “beneficiarles] of assets acquired through the forced uncompensated labors of enslaved African-Americans.” Id. ¶¶ 161, 165, 166, and 168. Plaintiffs allege that Canadian National Railway “is the successor-in-interest to seven predecessor railroad lines that were constructed or run in part by slave labor.” Id. ¶ 169. Plaintiffs further allege that “Canadian National engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise.” Id. ¶ 171. Plaintiffs allege that Southern Mutual Insurance “issued policies on the lives of slaves in Louisiana.” Id. ¶ 172. Plaintiffs allege that “AIG is successor-in-interest to the United States Life Insurance Company ..., which earned premiums from its sale of life insurance on the lives of enslaved Africans with slave owners as the beneficiaries.” Id. ¶ 173. As evidenced by Plaintiffs’ allegations, and as the court shall further discuss, their Complaint is devoid of any allegations that connect the specifically named Defendants or their predecessors and any of the Plaintiffs or their ancestors. B. Pleadings 1. Factual Allegations of Plaintiffs’ First Amended and Consolidated Complaint Plaintiffs’ Complaint begins with a narration of the historical background of the Transatlantic Slave Trade in America. The Complaint proceeds to describe the Slave Codes, which various States enacted in order to perpetuate the institution of slavery. The Complaint also chronicles how the forced labor of enslaved Africans helped to build our Nation and enrich early American industry, while simultaneously dismantling a culture and impoverishing a race of fellow men and women. The Complaint then outlines the beginnings of laws that outlawed the trafficking and trade of slaves, which progressed into a body of law that found the institution of slavery to be contrary to the Natural Law of Man. The Complaint proceeds to show that despite this body of law that found the institution of slavery to be contrary to the Natural Law of Man, the vestiges of slavery, in the form of racism, have resulted in modern-day disparities between descendants of slaves and the remainder of our society. Ultimately, the Complaint alleges that “Defendants, through their predecessors in interest, conspired and/or aided and abetted with slave traders, with each other and other entities and institutions ... and other unnamed entities and/or financial institutions to commit and/or knowingly facilitate crimes against humanity, and to further illicitly profit from slave labor.” See id. ¶ 53. 2. Counts of Plaintiffs’ First Amended and Consolidated Complaint Count I of Plaintiffs’ First Amended and Consolidated Complaint is styled: “Conspiracy.” Plaintiffs allege that “[e]ach of the defendants acted individually and in concert with their industry group and with each other, either expressly or tacitly, to participate in a plan that was designed in part to commit the tortious acts referred to herein.” Id. ¶ 216. Count II is styled: “Demand for an Accounting.” Plaintiffs allege that “Defendants knew or should have known of the existence of corporate records that indicate their profiting from slave labor[, and] Plaintiffs and the public have demanded that the defendants reveal them complete corporate records regarding same and that a just and fair accounting be made for profits derived from the slave trade.” Id. ¶ 219. Plaintiffs further allege that “[t]here is a fiduciary relationship that arose between the litigant classes and defendants by virtue of defendants’ superior position, maintenance of those positions and, their holding in constructive trust, the proceeds of the unpaid labor of the plaintiffs and / or their ancestors.” Id. ¶ 222. Plaintiffs argue that the production of such corporate records is essential in order to help Plaintiffs to: “heal the continuing psychic harm associated with slavery, trace ancestral records, provide a public and historical record of the violent force necessary to maintain a hierarchy to support slavery, provide evidence of past and subsequently established discrimination, provide a historical record of the economic benefits that accrued to the defendant private institutions as a result of slavery to more fully describe and document the connection between the institution of slavery and racist/discriminatory policies that still exist today, and assist in stemming racial discrimination through the knowledge of the role slavery played in its root causes.” Id. ¶ 221(a-f). Plaintiffs’ prayer for relief under Count II seeks, among other things, “the appointment of an independent historic commission to serve as a depository for corporate records related to slavery.” Id. ¶ 223. Count III is styled: “Crime Against Humanity.” Plaintiffs allege that “[slavery is and has always been a crime against humanity.” Id. ¶ 224. Count IV is styled: “Piracy.” Plaintiffs allege that “Defendants, upon information and belief[,] committed the crime against humanity by their actions either directly or indirectly in support for the continuation of the smuggling of Africans.” Id. ¶ 230. Plaintiffs’ prayer for relief under Count IV seeks an accounting of profits earned from slave labor, a constructive trust imposed on such profits, restitution, equitable disgorgement, and punitive damages. See id. ¶ 231. Count V is styled: “Intentional Infliction of Emotional Distress: Rape, Breeding, Torture, Abuse and the Spread of Racist Beliefs.” Plaintiffs allege that “Defendants’ predecessor companies aided or abetted, or under other theories of third party liability ..., participated in, allowed, or implicitly or recklessly, sanctioned, and/or benefitted from an institution that relied in [sic.] the sexual exploitation, violent abuse and rape to achieve its goals of a malleable and unpaid work force.” Id. ¶ 233. Plaintiffs further allege that “Defendants’ predecessor companies aided or abetted, or under other theories of third party liability ..., participated in, allowed implicitly or recklessly and / or unjustly benefitted from” the spread of racist ideology concerning the inferiority of the African race. Id. ¶ 236. Plaintiffs’ prayer for relief under Count V seeks an accounting of profits earned from slave labor, a constructive trust imposed on such profits, restitution, equitable disgorgement, and punitive damages. Id. ¶ 238. Count VI is styled: “Conversion.” Plaintiffs allege that “[a]s a result of defendants’ failure and refusal to account for, acknowledge and return to plaintiffs and the plaintiff class, the value of their ancestors’ slave labor, defendants have wilfully and wrongfully misappropriated and converted the value of that labor and its derivative profits into defendant’s own property.” Id. ¶ 240. Plaintiffs’ prayer for relief under Count VI seeks an accounting of profits earned from slave labor, a constructive trust imposed on such profits, restitution, equitable disgorgement, and punitive damages. See id. ¶ 242. Count VII is styled: “Unjust Enrichment.” Plaintiffs allege that “Defendants’ failure to pay for the labor provided by the slaves without receiving any compensation, has allowed defendants to retain a benefit at the expense of the plaintiffs’ and their ancestors.” Id. ¶ 247. Plaintiffs’ prayer for relief under Count VII seeks an accounting of profits earned from slave labor, a constructive trust imposed on such profits, restitution, equitable disgorgement, and punitive damages. See id. ¶ 253. Count VIII is styled: “42 U.S.C. § 1982.” Plaintiffs allege that as a result of the Defendants’ conduct that denied slaves of the value of their labor, and the Defendants’ conduct in restricting access to corporate records regarding participation in slavery, the Plaintiffs’ ancestors’, and their descendants’, rights to inherit and convey property have been violated in contravention of 42 U.S.C. § 1982. See id. ¶¶ 255-56. Count IX, which is pled in the alternative, is styled: “Alien Torts Claims Act.” Plaintiffs posit that, as “[m]any of the torts set out in the instant complaint occurred prior to the formal end of chattel slavery in the United States of America,” id. ¶ 237, Plaintiffs’ ancestors were not citizens of the United States at such a time. See id. ¶ 238. Plaintiffs further allege that slavery and international slave trafficking violated international law, and that since their ancestors were non-citizens, the Alien Torts Claims Act provides a source to relief for those violations of international law. See id. ¶¶ 237-43. Lastly, Counts X through XIV of the Plaintiffs’ Complaint allege that the factual allegations constitute violations of various state consumer protection laws. Specifically, Count X alleges a violation of the Illinois Consumer Fraud and Deceptive Business Practices Act, 815 Ill. Comp. Stat. 505/1 et seq. (2003); Count XI alleges a violation of the Louisiana Unfair Trade Practices and Consumer Protection Law, La.Rev.Stat. .Ann. § 51:1401 et seq. (2003); Count XII alleges a violation of the New Jersey Unfair Trade Practice Law, N.J. Stat. Ann. § 56:8-1 (2003); Count XIII alleges a violation of the New York Consumer Protection From Deceptive Acts and Practices Law, N.Y. Gen. Bus. Law §§ 349-350 (2003); and Count XIV alleges a violation of the Texas Deceptive Trade Practices and Consumer Protection Act, Tex. Bus. and Com. Code Ann. § 17.41 (2002). See FACC ¶¶ 244-253. In essence, the- Plaintiffs seek reparations from Defendants for their alleged roles in the institution of human chattel slavery as it. existed in the United States from 1619 through 1865, to date. 3. Defendants’ Joint Motion to Dismiss Defendants have responded to Plaintiffs’ Complaint with the present Motion to Dismiss, brought pursuant to Federal Rules of Civil Procedure 12(b)(1) and (6). See Defs.’ Joint Mot. to Dismiss, at 1. Defendants allege four separate grounds which warrant dismissal: (1) Plaintiffs’ claims fall short of both constitutional and prudential standing requirements; (2) Plaintiffs’ claims present a non-justiciable political question; (3) Plaintiffs’ claims fail to state any cognizable claim; and (4) all of Plaintiffs’ claims are time-barred. See id., at 4-5. Defendants’ motion is fully briefed and now before the court. IV. DISCUSSION A. Justiciability Doctrines Article III, § 2 of the United States Constitution provides that federal courts have jurisdiction only if presented with a “Case” or “Controversy.” The requirement of a case or controversy imposes a “dual limitation” upon the federal courts. See Flast v. Cohen, 392 U.S. 83, 94, 88 S.Ct. 1942, 20 L.Ed.2d 947 (1968). First, the requirement of a case or controversy serves to “limit the business of federal courts to questions presented in an adversary context and in a form historically viewed as capable of resolution through the judicial process.” Id. Second, the requirement of a case or controversy serves to “define the role assigned to the judiciary in a tripartite allocation of power to assure that the federal courts will not intrude into areas committed to the other branches of government.” Id. This “dual limitation” found in the requirement of a case or controversy is enforced by what have been termed the justiciability doctrines of Article III, which state the fundamental limits on federal judicial power in our system of government. See Allen v. Wright, 468 U.S. 737, 750, 104 S.Ct. 3315, 82 L.Ed.2d 556 (1984). “Concerns of justiciability go to the power of the federal courts to entertain disputes, and to the wisdom of their doing so.” Renne v. Geary, 501 U.S. 312, 316, 111 S.Ct. 2331, 115 L.Ed.2d 288 (1991). The justiciability doctrines include principles such as the prohibition against advisory opinions, standing, ripeness, mootness, and the political question doctrine. See generally Erwin Chemerinsky, Constitutional Law: Principles and Policies 46 (Aspen Law & Business 1997). “The Article III doctrine that requires a litigant to have ‘standing’ to invoke the power of a federal court is perhaps the most important of these doctrines.” Allen, 468 U.S. at 750, 104 S.Ct. 3315. 1. Standing The doctrine of standing ensures that a litigant is the proper party to bring a matter before a federal court for adjudication, by asking if that specific litigant has a sufficient stake in the matter to invoke the federal judicial process. As the United States Supreme Court recently reiterated: “We have consistently stressed that a plaintiffs complaint must establish that he has a ‘personal stake’ in the alleged dispute, and that the alleged injury suffered is particularized as to him.” Raines v. Byrd, 521 U.S. 811, 819, 117 S.Ct. 2312, 138 L.Ed.2d 849 (1997). a. Historical Overview of the Doctrine of Standing The requirement that a litigant demonstrate standing' — -a personal stake in an alleged dispute' — to bring a matter before a court for adjudication has been a bedrock principle in our system of law, as well as the common law system from which our system of law developed. The- standing doctrine comes from the well-known common law doctrine of locus standi, which translated from Latin means “place of standing.” In essence, the doctrine of locus standi concerns whether an individual has the legal capacity to institute proceedings. See, e.g., S.M. Thio, Locus Standi and Judicial Review 13-14, 235-36 (1971) (analyzing the doctrines of standing in the United States and in other common law countries). The concept of standing, or locus standi, was well known to the early federal courts. See, e.g., Southern Exp. Co. v. Western N.C.R. Co., 99 U.S. 191, 201, 9 Otto 191, 25 L.Ed. 319 (1878) (holding that since appellant had no legally cognizable interest in the suit, appellant “can, therefore, have no locus standi in a court of equity”). The standing doctrine serves to reinforce that “[t]he province of the court is, solely, to decide on the rights of individuals-” Marburg v. Madison, 5 U.S. (1 Cranch) 137, 170, 2 L.Ed. 60 (1803). As stated in an authoritative nineteenth century treatise: “The general rule is that the action should be brought in the name of the party whose legal right has been affected, against the party who committed or caused the injury, or by or against his personal representative.” Joseph Chitty, A Treatise on Pleading and Parties to Actions 1 (G. & C. Merriam 1867). In specific reference to tort actions, that treatise provides: The action for a tort must in general be brought in the name of the person whose legal right has been affected, and who was legally interested in the property at the time the injury thereto was committed; for he is impliedly the party injured by the tort, and whoever has sustained the loss is the proper person to call for compensation from the wrongdoer. Id. at 59 (emphasis in original and footnotes omitted). This treatise was relied upon by the United States Supreme Court in Tyler v. Judges of Court of Registration, 179 U.S. 405, 407, 21 S.Ct. 206, 45 L.Ed. 252 (1900), in which the Supreme Court discussed the proper parties to litigation. In elucidating the standing doctrine’s focus on the rights of individuals, the Tyler Court stated: The prime object of all litigation is to establish a right asserted by the plaintiff or to sustain a defense set up by the party pursued. Save in a few instances where, by statute or the settled practice of the courts, the plaintiff is permitted to sue for the benefit of another, he is bound to show an interest in the suit personal to himself, and even in a proceeding which he prosecutes for the benefit of the public, as, for example, in cases of nuisance, he must generally aver an injury peculiar to himself, as distinguished from the great body of his fellow citizens. Id. at 406, 21 S.Ct. 206. In Tyler, the Court reiterated that the doctrine of standing “has been announced in so many cases in this court that it may not be considered an open question.” Id. This core aspect of the doctrine of standing — that a litigant demonstrate a personal stake in an alleged dispute — has remained unchanged as the Supreme Court has elucidated the modern formulation and rationale for the doctrine. b. Modern Formulation of the Doctrine of Standing The standing doctrine involves both constitutional limitations on federal courts, based on Article III, and prudential limitations on the exercise of federal court jurisdiction. See, e.g., Warth v. Seldin, 422 U.S. 490, 498, 95 S.Ct. 2197, 45 L.Ed.2d 343 (1975). The modern formulation of the constitutional limitations of the standing doctrine was elucidated in Lujan v. Defenders of Wildlife, 504 U.S. 555, 112 S.Ct. 2130, 119 L.Ed.2d 351 (1992), where the Supreme Court stated: Over the years, our cases have established that the irreducible constitutional minimum of standing contains three elements. First, the plaintiff must have suffered an injury in fact — an invasion of a legally protected interest which is (a) concrete and particularized, and (b) actual or imminent, not conjectural or hypothetical. Second, there must be a causal connection between the injury and the conduct complained of — the injury has to be fairly traceable to the challenged action of the defendant and not the result of the independent action of some third party not before the court. Third, it must be likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560—61, 112 S.Ct. 2130 (citations and internal quotations omitted). “This triad of injury in fact, causation, and redressability constitutes the core of Article III’s case-or-controversy requirement.” Steel Co. v. Citizens For a Better Environment, 523 U.S. 83, 103-04, 118 S.Ct. 1003, 140 L.Ed.2d 210 (1998). These constitutional limitations on standing “are not confined to the facts of any particular case, but are broadly relevant to standing in any Article III controversy.” Plotkin v. Ryan, 239 F.3d 882, 884 (7th Cir.2001). The party seeking to invoke federal court jurisdiction has the burden of establishing the elements of standing. See Lujan, 504 U.S. at 561, 112 S.Ct. 2130. “Since they are not mere pleading requirements but rather an indispensable part of the plaintiffs case, each element must be supported in the same way as any other matter on which the plaintiff bears the burden of proof, i.e., with the manner and degree of evidence required at the successive stages of the litigation.” Id. The present motion is a motion to dismiss brought pursuant to Federal Rule of Civil Procedure 12(b), and in this posture “we must presume that the general allegations in the complaint encompass the specific facts necessary to support those allegations.” Citizens For a Better Environment, 523 U.S. at 104, 118 S.Ct. 1003. “However, [wjhere standing is challenged as a factual matter, the plaintiff bears the burden of supporting the allegations necessary for standing with competent proof.” Perry v. Village of Arlington Heights, 186 F.3d 826, 829 (7th Cir.1999) (quoting Retired Chicago Police Ass’n. v. City of Chicago, 76 F.3d 856, 862 (7th Cir.1996)) (internal quotations omitted); see also McNutt v. General Motors Acceptance Corp. of Indiana, 298 U.S. 178, 189, 56 S.Ct. 780, 80 L.Ed. 1135 (1936) (indicating that the party invoking federal court jurisdiction must “allege in his pleading the facts essential to show jurisdiction [and][i]f he fails to make the necessary allegations he has no standing”). “ ‘Competent proof requires a showing by a preponderance of the evidence that standing exists.” Id. (quoting NLFC, Inc. v. Devcom Mid-America, Inc., 45 F.3d 231, 237 (7th Cir.1995)); see also McNutt, 298 U.S. at 189, 56 S.Ct. 780 (stating that when “allegations of jurisdictional facts are challenged ... in any appropriate manner, [the party alleging jurisdiction] must support them by competent proof;” and if unchallenged, the federal courts “may demand that the party alleging jurisdiction justify his allegations by a preponderance of evidence”). c. Plaintiffs’ Allegations in Support of their Standing to Maintain this Suit In general, Plaintiffs claim that the source of their injury is the institution of slavery. Plaintiffs point to three distinct injuries which they allege are sufficient to confer them standing to maintain this suit. First, “the complaint alleges that enslaved African-Americans suffered concrete injury to their property and tort rights and that their descendants suffer derivative harm today.” Pis.’ Resp. to Defs.’ Mot. to Dismiss, at 3. Specifically, Plaintiffs allege injury through being “denied the economic wealth of their ancestors’ labor,” which they refer to as a “derivative and inherited property right in their ancestors’ lost pay.” FACC ¶¶ 100-01. Second, Plaintiffs allege that they are injured on a continuing basis. Specifically, Plaintiffs allege that “[t]hey still endure daily indignities from the legacy of slavery, including, but not limited to, racial profiling, racial slurs, and improper and hurtful assumptions regarding their overall status.” Id. ¶ 102. Further, Plaintiffs allege that they “are also likely to encounter future harm, as they are more likely to have a shorter life expectancy; more likely [to] go to jail; and are more likely to be murdered, than their white counterparts.” Id. Third, Plaintiffs’ allege that they are “[presently consumers of Defendants” and have been injured by certain communications made by the Defendants concerning their respective roles in the institution of slavery. See id. ¶ 93. Specifically, Plaintiffs allege that “[d]ue to unconscionable, fraudulent and deceptive public communications made by defendants, plaintiffs suffered the harm of being misled, confused, and deceived about the roles the defendants played in the enslavement of African peoples.” Id. Further, Plaintiffs allege injury through the Defendants’ refusal to provide documentation that relates to any profits made as a result of the institution of slavery. See Pis.’ Resp. to Defs.’ Mot. to Dismiss, at 12. (1). Constitutional Limitations on Standing (a). Derivative Harm It is well-established that a plaintiff must ‘“show that he personally has suffered some actual or threatened injury as a result of the putatively illegal conduct of the defendant.’ ” Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., 454 U.S. 464, 472, 102 S.Ct. 752, 70 L.Ed.2d 700 (1982) (quoting Gladstone, Realtors v. Village of Bellwood, 441 U.S. 91, 99, 99 S.Ct. 1601, 60 L.Ed.2d 66 (1979)). Plaintiffs cannot establish a personal injury by merely identifying tort victims and alleging a genealogical relationship. The illegal conduct at issue here, the institution of slavery, is alleged to have directly affected Plaintiffs’ ancestors. Plaintiffs now, more than a century later, point to that horrific institution as the source of their derivative injury. However, Plaintiffs’ own choice of words, derivative, should be sufficient to signify the standing problem in this case. See FACC ¶¶ 100-01; see also Pis.’ Resp. to Defs.’ Mot. to Dismiss, at 3. Plaintiffs fail to allege that they have personally suffered a concrete and particularized injury as a result of Defendants’ putatively illegal conduct; rather, Plaintiffs’ alleged injury is derivative of the injury inflicted upon enslaved African-Americans over a century ago. This is insufficient to establish standing, and contrary to centuries of well-settled legal principles requiring that a litigant demonstrate a personal stake in an alleged dispute. See, e.g., Tyler, 179 U.S. at 406-07, 21 S.Ct. 206 (stating that a plaintiff must “aver an injury peculiar to himself, as distinguished from the great body of his fellow citizens”); Lujan, 504 U.S. at 560, 112 S.Ct. 2130 (stating that a “plaintiff must have suffered an injury in fact — an invasion of a legally protected interest which is ... concrete and particularized”); Raines, 521 U.S. at 819, 117 S.Ct. 2312 (stating that “a plaintiffs complaint must establish that he had a ‘personal stake’ in the alleged dispute, and that the alleged injury is particularized as to him”). To recognize Plaintiffs’ standing in such a situation “would transform the federal courts into ‘no more than a vehicle for the vindication of the value interests of concerned bystanders.’ ” Allen, 468 U.S. at 756, 104 S.Ct. 3315 (citing United States v. SCRAP, 412 U.S. 669, 687, 93 S.Ct. 2405, 37 L.Ed.2d 254 (1973)). In addition, the injury alleged cannot be “conjectural or hypothetical.” Lujan, 504 U.S. at 560, 112 S.Ct. 2130. Plaintiffs allege injury through being “denied the economic wealth of their ancestors’ labor,” which they refer to as a “derivative and inherited property right in their ancestors’ lost pay.” FACC ¶¶ 100-01. However, Plaintiffs’ claim to the economic wealth of their ancestors’ labor is conjectural. While most would like to assume that they will be the beneficiaries of their ancestors’ wealth upon their demise, this is a mere assumption. Plaintiffs can only speculate that their ancestors’ estates would have been passed on to them, and cannot say that they would have inherited their ancestors’ lost pay. This is insufficient to show a personal injury to Plaintiffs. Further, the Plaintiffs must allege a “causal connection between the injury and the conduct complained of.” Lujan, 504 U.S. at 560, 112 S.Ct. 2130. “[T]he injury has to be fairly traceable to the challenged action of the defendant, and not the result of the independent action of some third party not before the court....” Id. The allegations of Plaintiffs’ Complaint do not link these Defendants to the alleged harm. Plaintiffs fail to allege any facts in their Complaint that link the specifically named Defendants to the alleged injuries suffered by the Plaintiffs; nor does the Plaintiffs’ Complaint allege a connection between any of the named Defendants and any of the Plaintiffs’ ancestors. The named Plaintiffs who allege that they are descendants of enslaved African-Americans fail to allege that them ancestors were enslaved by any of the eighteen specifically named Defendants. Likewise, the named Plaintiffs who allege that they were slaves fail to allege that they were enslaved by any of the eighteen specifically named Defendants. Plaintiffs’ only response to this fundamental defect is to allege that Defendants were engaged in “co-dependent” industries and therefore vicariously liable for the institution of slavery. However, Plaintiffs fail to allege how these named Defendants were involved in these “co-dependent” industries. Plaintiffs offer no allegations that Defendants had any relationships with specific entities that enslaved Plaintiffs or their ancestors. More than “unadorned speculation” is required to establish standing. See Simon v. Eastern Kentucky Welfare Rights Org., 426 U.S. 26, 43-44, 96 S.Ct. 1917, 48 L.Ed.2d 450 (1976). (b). Continuing Injury Plaintiffs’ allegations that they suffer injury on a continuing basis also fail to establish the requisite standing. Plaintiffs claim a continuing injury through the allegation that “[tjhey still endure daily indignities from the legacy of slavery, including, but not limited to, racial profiling, racial slurs, and improper and hurtful assumptions regarding their overall status.” FACC ¶ 102. Further, Plaintiffs allege that they “are also likely to encounter future harm, as they are more likely to have a shorter life expectancy; more likely [to] go to jail; and are more likely to be murdered, than their white counterparts.” Id. Plaintiffs’ allegations of continuing harm are no different than the allegations of continuing harm made by the plaintiffs in Cato v. United States, 70 F.3d 1103 (9th Cir.1995), and other similar cases. In Cato, descendants of enslaved African-Americans filed a complaint against the United States government seeking damages due to the enslavement of, and subsequent discrimination against, African-Americans. Cato, 70 F.3d at 1105. The plaintiffs in Cato alleged injuries based on “disparities in employment, income, and education” between African-Americans and other racial groups. Id. at 1109. The Cato court found that such allegations were insufficient to establish an injury personal to the plaintiffs so as to establish the plaintiffs’ standing; rather, such injuries were “a generalized, class-based grievance .... ” Id. Other courts faced with similar complaints have also found that those plaintiffs had failed to establish their standing to litigate claims based on continuing injuries alleged to be the result of slavery. See, e.g., Bell v. United States, No. Civ. A. 301CV0338D, 2001 WL 1041792, at *2 (N.D.Tex. Aug.31, 2001) (plaintiff lacked standing to file suit against United States government seeking damages for the enslavement of African-Americans); Bey v. United States Department of Justice, No. 95 CIV 10401, 1996 WL 413684, at *1 (S.D.N.Y. July 24, 1996) (same); Langley v. United States, No. C 95-4227, 1995 WL 714378, at *2 (N.D.Cal. Nov.30, 1995) (same); Himiya v. United States, No. 94 C 4065, 1994 WL 376850, *2 (N.D.Ill. July 15, 1994) (“Although it is extremely regrettable that this country’s history, as well as the history of many other countries, includes a significant history of slavery, the plaintiff does not have proper standing under the law to recover damages for this reprehensible time period.”). Like -the plaintiffs’ allegations in Cato and the other slavery reparations cases decided after Cato, Plaintiffs’ allegations of continuing harm in this case do not establish a concrete and particularized injury-in-fact, as these allegations are too speculative and generalized. See Lujan 504 U.S. at 560-61, 112 S.Ct. 2130. Plaintiffs argue that the other lawsuits seeking reparations for acts related to the institution of slavery are distinguishable on the grounds that those cases were brought by pro se plaintiffs, acting without the guidance of counsel, and against the United States Government, protected from suit by the doctrine of sovereign immunity. These are distinctions without a difference. Those pro se plaintiffs could have been represented by attorneys and the result would not have changed. Furthermore, the doctrine of sovereign immunity was only one of many jurisdictional bars to suit in those cases, including standing. The constitutional limitations on standing, including an injury-in-fact, “are not confined to the facts of any particular case, but are broadly relevant to standing in any Article III controversy.” Plotkin, 239 F.3d at 884. Like the plaintiffs in those cases, Plaintiffs fail to allege any concrete and particular injury-in-fact that they have suffered apart from their race generally. Further, Plaintiffs’ complaint is devoid of any allegations that any specific conduct of the Defendants was a cause of the continuing injuries of which Plaintiffs complain. Such wide-ranging social ills are not even alleged “to be fairly traceable to the challenged action of the defendant, and not the result of the independent action of some third party not before the court.” Lujan, 504 U.S. at 560, 112 S.Ct. 2130. Plaintiffs’ allegations of abstract stigmatic injury are not cognizable absent specific allegations of conduct on behalf of the Defendants that has been directed at Plaintiffs or their ancestors. Cf. Allen, 468 U.S. at 755-56, 104 S.Ct. 3815. (c). Miscellaneous Injury Lastly, Plaintiffs allege injury, in their status as consumers of the Defendants, through being misled, confused and deceived about the roles the Defendants played in the enslavement of African peoples, as a result of Defendants’ public communications. See FACC ¶ 93. Plaintiffs also allege a separate harm through the Defendants not turning over documents that relate to their involvement in securing profits from slavery. See id. ¶¶ 218-23. These alleged injuries relate to causes of action plead in Plaintiffs’ Complaint as violations of various state consumer protection laws. See id., Counts X-XIV. Plaintiffs argue that their allegations that Defendants have violated these State consumer protection laws are sufficient to confer them standing to pursue these, and all other, claims. See Pis.’ Resp. to Defs.’ Mot. to Dismiss, at 11. Further, Plaintiffs argue that some of these statutes do not even require that an injury be alleged, and therefore their standing to pursue all claims is a given. See id. This argument misses the mark. The fact that a state statute dispenses with the requirement that an injury be alleged does not, and cannot, abrogate constitutional limitations imposed by Article III that a personal injury-in-fact is a prerequisite for standing to sue in a federal court. See, e.g., Burford v. Sun Oil Co., 319 U.S. 315, 317, 63 S.Ct. 1098, 87 L.Ed. 1424 (1943) (holding that state legislatures may not expand the jurisdiction of the federal district courts); see also Rifkin v. Bear Stearns & Co., Inc., 248 F.3d 628, 631 (7th Cir.2001) (same). These constitutional limitations on standing cannot be altered by either state or federal law. See Gladstone, Realtors, 441 U.S. at 100, 99 S.Ct. 1601 (holding that Congress may not abrogate the constitutional limitations on standing); Watson v. Tarpley, 59 U.S. 517, 520, 18 How. 517, 15 L.Ed. 509 (1855) (holding that “[state] laws cannot affect, either by enlargement or diminution, the jurisdiction of the courts of the United States as vested and prescribed by the constitution and laws of the United States”); see also U.S. Const. art. VI, cl. 2 (Supremacy Clause). Further, Plaintiffs cannot use their standing to pursue one type of claim in a State court in order to establish them standing to pursue all of the claims asserted in the present case in a federal court. “The plaintiffs must establish the district court’s jurisdiction over each of their claims independently; they are not permitted to use one count of their complaint to establish federal subject matter jurisdiction and a separate count to establish standing.” Rifkin, 248 F.3d at 634. Moreover, these injuries alleged in Plaintiffs’ status as consumers of Defendants do not establish a legally cognizable injury. Aside from alleging a general state of confusion, the Plaintiffs fail to allege any injury-in-fact that has come about as