United States Ninth Circuit
Doe v. Nestle USA, Inc., 10-56739
In a suit brought by former child slaves from the Ivory Coast under the Alien Tort Statute (ATS) against defendants, alleging that defendants aided and abetted child slavery, the district court's dismissal of plaintiffs' complaint is reversed, vacated, and remanded for further proceedings, where: 1) the prohibition against slavery was universal and could be asserted against the corporate defendants in this case; 2) plaintiffs' allegations satisfied the "purpose" standard by suggesting that a myopic focus on profit over human welfare drove the defendants to act with the purpose of obtaining the cheapest product, even if it meant facilitating child slavery; and 3) substantial assistance must be offered by defendants to satisfy aiding and abetting, but the case is remanded to the district court to allow plaintiffs to amend their complaint to address the "specific direction" requirement.
Appellate Information
- Decided 09/04/2014
- Published 09/04/2014
Judges
- Nelson
Court
- United States Ninth Circuit