The 9th U.S. Circuit Court of Appeals in 2018 ruled that business practices involved in acquiring cocoa in West Africa contravened the Alien Tort Act enacted in 1789.  The case involves a claim alleging that child labor was used to produced cocoa and that workers were forced to labor on farms against their will.

The Alien Tort Statute allows non-U.S. citizens to seek damages in American courts.

A Federal district court in Los Angeles dismissed the lawsuit in 2017 but it was revived by the 9th Circuit in 2018 ruling that payments made to farmers for cocoa was in fact dependent on child slave labor.

Previously the Supreme Court ruled that plaintiffs were ineligible to claim under the Alien Tort Statue for human rights violations.