Case Citator › Aldana v. Del Monte Fresh Produce, N.A., Inc.

Aldana v. Del Monte Fresh Produce, N.A., Inc.

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Eleventh Circuit
Citation
416 F.3d 1242
Decided
Confirmed treatments
5
Flagged citations read
45 of 45
Citing cases (total)
45
Treatment dates
2008–2012
Overruled in part
A reviewed court has overruled part of this case’s holding. Aldana v. Del Monte Fresh Produce, N.A., Inc. was overruled in part on corporate liability under the Torture Victim Protection Act. The Supreme Court's later decision in Mohamad v. Palestinian Authority held that the Act reaches natural persons only.
More on how this was screened

The Eleventh Circuit later recorded the effect of that rule on corporate defendants in Jane Doe v. Drummond Co. The Ninth Circuit had already rejected Aldana's contrary treatment of corporate defendants in Bowoto v. Chevron Corp. Two district courts declined to follow Aldana's rejection of Alien Tort Statute claims for cruel, inhuman, or degrading treatment, and another rejected its corporate liability ruling under the Torture Victim Protection Act. All five treatments are listed below. All 45 flagged citations have been read.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

45 later cases cite Aldana v. Del Monte Fresh Produce, N.A., Inc.; 45 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Aldana v. Del Monte Fresh Produce, N.A., Inc.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in Part

  • The Supreme Court held that the Torture Victim Protection Act reaches natural persons only, ending Aldana's contrary allowance of claims against corporations.

    Mohamad v. Palestinian Authority · Supreme Court of the United States · filed

    We hold that the term “individual” as used in the Act encompasses only natural persons. Consequently, the Act does not impose liability against organizations.
    Read the full opinion on CourtListener →

Declined to Follow

  • The district court rejected Aldana's conclusion that cruel, inhuman, and degrading treatment cannot support an Alien Tort Statute claim and allowed the claim to survive summary judgment.

    Bowoto v. Chevron Corp. · N.D. Cal. · filed

    the Eleventh Circuit in Aldana held that cruel, inhuman and degrading treatment does not meet the Sosa standard for actionable claims under the ATS. ... The Court finds Judge Barkett’s dissenting opinion more persuasive than the Eleventh Circuit panel opinion because it is consistent with Rosa and contains a well-reasoned analysis. ... Therefore, the Court holds as a matter of law that claims of cruel, inhuman and degrading treatment by plaintiffs are sufficient to survive a motion for summary judgment and DENIES defendants’ motion on this claim.
    Read the full opinion on CourtListener →

  • The District of Columbia district court held that the Torture Victim Protection Act's reference to an “individual” excluded organizational defendants, contrary to Aldana's allowance of a corporate claim.

    Mohamad v. Rajoub · D.D.C. · filed

    but see Aldana v. Del Monte Fresh Produce, N.A., Inc., ... (allowing a TVPA claims to be raised against corporations). Of course, this conclusion is also consistent with Congress’s decision to use the term “individual” in the TVPA to describe both those who commit torture and extrajudicial killings and those who are victims.
    Read the full opinion on CourtListener →

  • The Maryland district court found Aldana's analysis of cruel, inhuman, and degrading treatment unpersuasive.

    Al-Quraishi v. Nakhla · D. Md. · filed

    Because Aldana does not undertake analysis of international law in the manner which Sosa requires, this Court finds it unpersuasive. The majority in Aldana did not survey the sources of international law in evaluating CIDT.
    Read the full opinion on CourtListener →

  • The Ninth Circuit rejected Aldana's position on corporate liability under the Torture Victim Protection Act.

    Bowoto v. Chevron Corp. · Ninth Circuit · filed

    The 11th Circuit has said that corporations can be found liable under the TVPA. See Aldana v. Del Monte Fresh Produce, N.A., Inc., 416 F.3d 1242, 1250-52 (11th Cir.2005). ... We agree with the district court that Congress’s use of the word “individual” throughout the statute indicates that it did not intend for the TVPA to apply to corporations.
    Read the full opinion on CourtListener →

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