In re Estate of Alvarez v. Rockefeller Foundation, No. 22-1678 (4th Cir. 2024)
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This case was heard in the United States Court of Appeals for the Fourth Circuit and involved the Estate of Arturo Giron Alvarez and 773 other plaintiffs, who brought claims against The Rockefeller Foundation (TRF), alleging the foundation's involvement in nonconsensual human medical experiments in Guatemala from 1946 to 1948. The experiments involved exposing people to sexually transmitted diseases (STDs) to study the diseases and potential treatments. The defendants had previously filed a motion for summary judgment, which was granted by the district court. The plaintiffs appealed this decision, specifically challenging the decision relating to TRF.
The appeal hinged on the question of whether Dr. Soper, an Associate Director of TRF who was assigned to the Pan-American Sanitary Bureau (PASB) in Guatemala during the time of the experiments, was acting as an agent of TRF, thus making TRF liable for his actions. The court found that despite TRF paying Dr. Soper's salary during his time at the PASB, there was no indication that TRF was directing or controlling Dr. Soper’s work. Furthermore, the evidence showed that Dr. Soper considered himself no longer with TRF, and the PASB's constitution prohibited him from taking outside direction.
The court concluded that TRF's connection to the experiments was too tenuous to be held liable for them. It affirmed the district court's grant of summary judgment in favor of TRF, stating that Dr. Soper was not an agent of TRF during the time of the experiments.
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