Nestle USA, Inc. v. Doe
Case Overview
Six individuals who said they were trafficked as children and forced to work on cocoa farms in Ivory Coast sued Nestle USA and Cargill under the Alien Tort Statute, alleging the companies knowingly benefited from and perpetuated child slavery through their cocoa sourcing. The Supreme Court held 8-1 that the plaintiffs had not adequately alleged that the corporations' relevant conduct occurred in the United States, requiring dismissal.
The Facts
The plaintiffs alleged they had been trafficked from Mali and forced to work on cocoa farms in Ivory Coast that supplied Nestle and Cargill. They claimed the companies' domestic U.S. decision-making about purchasing practices, training programs, and technical assistance to farmers amounted to aiding and abetting child slavery in violation of international law, cognizable under the Alien Tort Statute. Both the district court and the Ninth Circuit dismissed.
The Conclusion
The Supreme Court held 8-1 that the plaintiffs failed to plausibly allege domestic conduct by the corporations sufficient to trigger ATS jurisdiction. General corporate policy-making in the United States, untethered to the specific harms in Ivory Coast, was not enough. The suit was dismissed.
No circuit court data for this case.
Flag an issue
This tracker is maintained by BrynoDC and is free because readers fund it. Support