Nestlé USA, Inc. v. Doe (U.S. Sup. Ct.)

Abstract

On June 17, 2021, the U.S. Supreme Court delivered its opinion in Nestlé USA, Inc. v. Doe, a human rights case brought under the Alien Tort Statute (ATS), alleging that U.S. companies aided and abetted child slavery in Ivory Coast. By a vote of 8 to 1, the Court held that the claims were impermissibly extraterritorial because nearly all the conduct occurred abroad. The Court left open the possibility that the implied cause of action under the ATS applies to U.S. corporations.