'No one can read the significant Supreme Court cases on sovereign immunity... without concluding that the field is a mass of confusion; and if he ventures beyond that to attempt some reconciliation of the courts of appeals decisions, he will find confusion compounded." '
Rios, Great L. and Flaherty, Edward P.
"International Organization Reform Or Impunity? Immunity Is The Problem,"
ILSA Journal of International & Comparative Law: Vol. 16
, Article 4.
Available at: https://nsuworks.nova.edu/ilsajournal/vol16/iss2/4