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Nestlé Usa, Inc.v.Doe

CourtSupreme Court of the United States
Docket No.19-416
DecidedJune 17, 2021
Reporter593 U.S. 628
JudgesSupreme Court of the United States
Tags
CivilCivil RightsTort LawFederal JurisdictionStatutory InterpretationConstitutional InterpretationReversal
Case Summary

Six people from Mali alleged that they had been trafficked as children to produce cocoa in Ivory Coast and sued Nestlé USA and Cargill under the Alien Tort Statute. The companies bought cocoa from overseas farms and provided technical and financial resources, while the complaint alleged that major operational decisions were made in the United States. The Supreme Court held that the claims sought an impermissibly extraterritorial application of the statute because nearly all conduct alleged to aid forced labor occurred abroad and general corporate decisionmaking did not supply the required domestic connection. The Court also concluded that federal courts should not create the requested corporate aiding-and-abetting cause of action where separation-of-powers and foreign-policy concerns counseled deference to Congress. It reversed and remanded the Ninth Circuit’s judgment. Multiple Justices wrote separately, including a dissent that would have addressed corporate liability rather than dismissing on extraterritoriality grounds.

Opinion

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Nestlé Usa, Inc. V. Doe — The Atlanta Gleaner