On January 11, 2016, the U.S. Supreme Court issued an order declining to review an appeals court decision that permits activists to go forward with a suit charging chocolate manufacturers with aiding and abetting human rights violations by farmers in the Ivory Coast. The order was a setback for WLF, which filed a brief urging review. The suit, filed on behalf of farm workers, claims that the manufacturers violated a 1789 statute, the Alien Tort Statute (ATS). WLF argued that such claims require evidence that the defendants’ “purpose” was to facilitate the alleged human rights violations, and that such a purpose may not be inferred simply because the manufacturers purchased cocoa from Ivory Coast farmers. WLF also argued that the ATS protects against human rights abuses that occur in the United States, not elsewhere; Congress did not adopt the statute for the purpose of making U.S. judges the arbiters of working conditions throughout the world.