Nestlé USA, Inc. v. Doe

141 S.Ct. 1931 (2021)

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Nestlé USA, Inc. v. Doe

United States Supreme Court
141 S.Ct. 1931 (2021)

  • Written by Tanya Munson, JD
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Facts

Six individuals from Mali (the individuals) (plaintiffs) claimed that they were trafficked as children to farms in Ivory Coast as child slaves to produce cocoa. The individuals brought suit in district court in the United States against Nestlé USA, Inc. (Nestlé) (defendant) under the Alien Tort Statute (ATS), alleging that Nestlé aided and abetted forced child labor. The individuals alleged that Nestlé provided training, fertilizer, tools, and cash to overseas farms that used forced child labor. All the conduct that the individuals alleged aided and abetted forced labor occurred in Ivory Coast. The individuals argued that because Nestlé aided and abetted child slavery, the ATS provided the United States federal courts with jurisdiction to hear the case. The individuals supported the domestic application of the ATS by pleading as a general matter that every major operational decision of Nestlé was made or approved in the United States. The district court dismissed the suit as impermissible extraterritorial application of the ATS. The individuals appealed, and the court of appeals reversed, holding that the individuals pleaded a domestic application of the ATS. Nestlé appealed.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

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