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Doe v. Unocal Corp.
United States Court of Appeals for the Ninth Circuit
395 F.3d 932 (2002)
Unocal Corporation (Unocal) (defendant) hired the Myanmar military to provide security and build infrastructure along the route of a gas pipeline that was under construction. Unocal and the Myanmar military used photos, maps, and surveillance to show the Myanmar military where to provide security and build infrastructure. The Myanmar military utilized forced labor to perform these services for Unocal. Nationals of Myanmar (Doe) (plaintiffs) filed a class-action lawsuit in district court against Unocal, claiming that Unocal aided and abetted the Myanmar military in subjecting Doe to forced labor. Doe alleged that Unocal paid the Myanmar military to provide security and labor for the construction of a gas pipeline in Myanmar and that Unocal knew that the Myanmar military would supply forced labor in violation of the Alien Tort Statute (ATS). The district court found that the evidence suggested that Unocal knew of and benefitted from the use of forced labor by the Myanmar military, but that Unocal was not liable because its conduct did not actively participate in the forced labor. Doe appealed, and Unocal filed a motion for summary judgment.
Rule of Law
Holding and Reasoning (Pregerson, J.)
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