In the case of Nestle USA v. Doe I, 2020, six individuals from Mali alleged that they were trafficked as child slaves to cocoa plantations in Ivory Coast which supplied cocoa to American companies including Nestlé USA and Cargill. The plaintiffs claimed these corporations aided and abetted their slavery by purchasing cocoa at a low cost knowing it was harvested by child slaves, providing financial and technical assistance with full knowledge of the situation. They brought their suit under the Alien Tort Statute (ATS), a law allowing foreign citizens to seek remedies in U.S courts for human-rights violations committed outside America's borders. However, the Supreme Court ruled 8-1 against them stating that allegations against domestic corporations must be more than just general corporate activity; there needs to be specific conduct connecting them directly with harm suffered overseas. This ruling effectively limited lawsuits against U.S.-based multinational corporations for alleged human rights abuses occurring abroad.

In the dissenting opinion for NESTLE USA v. DOE I, Justice Sonia Sotomayor argued that the majority's decision to dismiss the case was premature and overly broad in its interpretation of extraterritoriality. She contended that corporations should not be exempt from liability under the Alien Tort Statute (ATS) simply because they are domestic entities. The ATS, she noted, does not distinguish between individual and corporate defendants but rather focuses on conduct violating international law norms. Furthermore, she disagreed with the majority's view that all relevant conduct took place abroad; instead arguing there were allegations suggesting decisions aiding and abetting child slavery occurred within U.S borders by Nestle USA executives. Therefore, these claims could potentially touch upon U.S interests sufficiently enough to overcome any presumption against extraterritorial application of ATS as per previous rulings like Kiobel v Royal Dutch Petroleum Co., 2013.