West Africa is presently home to approximately 1.5 million acres of cocoa farmland, which subsequently produces 70% of the world’s current chocolate supply. Côte d’Ivoire, also known as the Ivory Coast, is one of the largest cocoa producing countries within West Africa.

The increase of farmland and the need to control the deteriorating conditions have always created a demand for farm workers. Regrettably, more than 1.5 million cocoa farm workers in West Africa are currently children. These child workers are exposed to hazardous dust, flames, smoke, and chemicals, are required to utilize dangerous tools that they are not properly trained to use, and are subject to various forms of physically demanding work. In the early 2000s, the Ivorian government ratified the International Labour Organization’s Convention Concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour (Convention 182).

The International Labor Rights Forum (ILRF), an organization that combats our world’s problems of worker’s rights and labor standards, decided to take legal action against companies who refused to follow protocols to eliminate the use of child slave labor on cocoa farms on the Ivory Coast. The ILRF partnered with several law firms across the nation, bringing forth causes of action under the Alien Tort Statute (ATS), the Torture Victim Protection Act (TVPA), and other state-related claims.

Part II of this case note discusses the ATS, its legislative history, and the various noteworthy case law that has interpreted the statute over time. Part III will discuss the scope of aiding and abetting liability for violations of international law and part IV will discuss the procedural history and legal reasoning behind the decisions of Doe v. Nestle, S.A. over the past sixteen years of litigation. Finally, this note will conclude with a personal analysis and prediction regarding the next steps of this case.