On June 17, 2021, the Supreme Court overturned a Ninth Circuit decision that would have allowed activists to impose liability on U.S. entities for aiding and abetting a third-party’s alleged human rights violations overseas. The decision was a victory for WLF, which filed an amicus brief in the case on behalf of itself and the Allied Educational Foundation. Citing evidence that the defendants, U.S.-based cocoa processors and chocolate manufacturers, exploited the lower prices available for cocoa harvested from Ivory Coast farms, the Ninth Circuit held that the defendants must stand trial for aiding and abetting human rights abuses under the Alien Tort Statute (ATS). In an 8-1 opinion, the Supreme Court reversed. The Court reiterated that nothing in the ATS rebuts the presumption of domestic application in federal law. And since the ATS does not apply extraterritorially, the plaintiffs must show that the relevant conduct occurred in the United States. Yet nearly all the relevant conduct in the plaintiffs’ complaint occurred in the Ivory Coast.