Doe I v. Nestlé U.S.A., Inc. (Ninth Circuit)

Plaintiffs sought damages from defendants under the Alien Tort Statute (ATS), alleging that defendants aided and abetted plaintiffs’ labor violations in foreign country. The legal issues involved in the case were (1) whether corporations could be held liable under the ATS; (2) whether a claim of aiding and abetting was cognizable under the ATS; (3) whether specific intent was required to prove the mens rea element under the ATS. The Ninth Circuit held that corporations may be held liable under the ATS, that defendants can face aiding and abetting liability under the ATS, and that plaintiffs were not required to prove specific intent.