Aldana v. Del Monte Fresh Produce, N.A., Inc.

Seven Guatemalan citizens (the Guatemalans) (plaintiffs) were officers in SITRABI, a national trade union of plantation workers in Guatemala. The Guatemalans represented workers on a banana plantation owned by Bandegua (defendant), a wholly owned subsidiary of Del Monte Fresh Produce, N.A., Inc. (Del Monte) (defendant). SITRABI was attempting to negotiate a new collective-bargaining agreement with Bandegua to cover the plantation workers. In the midst of negotiations, Bandegua hired a private, armed security force of 200 men, who arrived one evening at SITRABI’s headquarters. At Bandegua’s direction, the Guatemalans were held hostage, threatened with death, shoved with guns, and forcibly detained at SITRABI’s headquarters for over eight hours. Two of the Guatemalans were compelled at gunpoint to publicly denounce the union, announce that the labor dispute was over, and sign resignation forms. Subsequently, the Guatemalans moved to the United States, where they filed a civil action in district court against Del Monte and Bandegua under the Alien Tort Act, based on the events in Guatemala. The district court granted Del Monte’s motion to dismiss the complaint for failure to state a claim, and the Guatemalans appealed. On appeal, the Guatemalans argued that Del Monte and Bandegua had engaged in systematic and widespread efforts to oppose organized labor in addition to the allegedly unlawful conduct on the night in question.