## Facts

- Adult and child Liberian plantation workers sued corporate and individual defendants connected to ownership and operation of a rubber plantation in Liberia, proceeding under pseudonyms.
- Adult plaintiffs alleged low wages and high daily production quotas effectively required them to use their children’s labor to meet quotas.
- Plaintiffs alleged economic pressure from widespread unemployment in Liberia made them fear job loss and unable to resist plantation demands.
- Child plaintiffs (approximately ages six to sixteen) alleged they performed long hours of hazardous work, including carrying heavy loads and working with or around toxic agricultural chemicals.
- Adult plaintiffs did not allege wages were withheld, that they were physically restrained, that they were legally prevented from leaving, or that physical violence was used to compel continued work.
- Plaintiffs sought relief under the Alien Tort Statute (ATS) based on alleged violations of international-law norms prohibiting forced labor and child labor, along with additional federal and state-law theories.

## Issues

1. Whether the ATS provided subject-matter jurisdiction over claims by foreign plaintiffs alleging international-law violations occurring abroad.
2. Whether allegations of low pay, harsh quotas, and fear of unemployment stated an ATS claim for “forced labor” under a specific, universal, and obligatory international-law norm.
3. Whether allegations that young children performed hazardous plantation work stated an ATS claim under a universally accepted norm prohibiting the worst forms of child labor.
4. Whether plaintiffs stated viable claims under the Thirteenth Amendment, 18 U.S.C. § 1595, and asserted state-law causes of action.

## Decision

- The court denied dismissal for lack of subject-matter jurisdiction, holding the ATS could supply jurisdiction for properly pleaded international-law claims.
- The court dismissed the adult forced-labor claim for failure to state a claim, concluding the alleged pressure was economic necessity rather than employer-imposed coercion meeting international definitions of forced labor.
- The court allowed the ATS child-labor claim to proceed, finding allegations of hazardous work by young children plausibly implicated a sufficiently definite and widely accepted international norm.
- The court dismissed the remaining claims, including Thirteenth Amendment, 18 U.S.C. § 1595, and state-law claims.

## Legal Principles

- ATS adjudication is limited to claims grounded in international-law norms that are “specific, universal and obligatory,” as required by Sosa.
- Under widely cited international standards (including ILO Convention No. 29), forced labor requires work exacted under a “menace of any penalty” and not offered voluntarily; low wages, poor conditions, or lack of alternatives alone do not satisfy that requirement.
- A broadly accepted international norm prohibits the worst forms of child labor, including hazardous work by young children; sufficiently detailed allegations of such hazardous child labor can state an ATS claim.
- Constitutional and statutory forced-labor remedies (including Thirteenth Amendment theories and § 1595) require allegations fitting those legal frameworks; absence of coercion akin to slavery, peonage, or trafficking-type compulsion may be fatal at the pleading stage.

## Conclusion

The court held that the ATS could confer jurisdiction but dismissed all claims except the ATS claim alleging hazardous child labor, drawing a sharp line between economic pressure and forced labor while recognizing hazardous child labor as actionable under a definite and widely accepted international-law norm.


John Roe I v. Bridgestone Corp., 492 F. Supp. 2d 988 (S.D. Ind. 2007)