Commentary on successful use of Trafficking Victims Protection Reauthorization Act in case of forced labour claims against US construction cos. in Qatar
"Court Allows Claims of Forced Labor to Build World Cup Stadiums", 30 July 2025
On June 26, 2025, in F.C. v. Jacobs Solutions Inc., Magistrate Judge Cyrus Y. Chung (District of Colorado) partly granted and partly denied a motion to dismiss claims against U.S. companies under the Trafficking Victims Protection Reauthorization Act (TVPRA) alleging their participation in a venture that used forced labor to build stadiums in Qatar for the 2022 World Cup...
The plaintiffs, Filipino migrant workers, helped build five stadiums in Qatar, allegedly under conditions that constituted forced labor. The defendant companies, a U.S. engineering firm and its subsidiaries, were not the contractors. Rather, the defendants were hired to manage the contractors and to ensure that they followed proper labor standards...
... The TVPRA was first enacted in 2000, adding crimes of forced labor, human trafficking, and sex trafficking to a chapter of the federal criminal code with various slavery offenses. In 2003, Congress created a civil cause of action, allowing victims of the three new crimes to sue perpetrators for damages...
...Congress expanded the extraterritorial application of the TVPRA, expressly providing in § 1596(a) that six of its criminal offenses, including slavery, forced labor, human trafficking, and sex trafficking apply extraterritorially when “an alleged offender” is a U.S. national, U.S. permanent resident, or otherwise present in the United States...
...Judge Chung dismissed some of the defendants for lack of personal jurisdiction and some of the claims as impermissibly extraterritorial. But critically, he allowed claims for benefiting from forced labor under § 1589(b) to move forward against some defendants...
... The TVPRA covers only some kinds of human rights claims. But human trafficking and forced labor remain significant problems around the world. By allowing civil claims against companies in the United States that knowingly benefit from forced labor abroad, the TVPRA provides a powerful tool for corporate accountability in this important area.