Chevron Corp. v. Naranjo
667 F.3d 232
2d Cir.2012Background
- Chevron sought a global anti-enforcement injunction under New York's Uniform Foreign Country Money-Judgments Recognition Act against the Lago Agrio Plaintiffs and Donziger to bar enforcement of an Ecuadorian judgment outside Ecuador.
- The district court granted the injunction on March 7, 2011; this Court previously vacated and stayed proceedings.
- Chevron relied on the Recognition Act to argue the Ecuadorian judgment should be declared nonrecognizable and enjoined from enforcement.
- The Ecuadorian judgment rests on a contested trial with alleged fraud and political interference; an intermediate Ecuadorian court decision upheld the trial court’s ruling.
- The court held that the Recognition Act cannot support an affirmative pre-enforcement declaration or injunction, and remanded with instructions to dismiss Chevron’s Recognition Act claim.
- The appellate decision reverses the district court’s injunction and dismisses Chevron’s claim, making further issues moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Recognition Act authorizes pre-enforcement injunctions | Chevron argues the Act permits preemptive relief. | LAPs/Donziger contend the Act only allows defenses when enforcement is sought. | No; the Act does not authorize pre-enforcement declarations or injunctions. |
| Whether international comity supports the injunction | Chevron asserts comity concerns justify global enforcement barriers. | LAPs/Donziger argue comity weighs against preemptive enforcement blocks. | Comity considerations exist but are insufficient to sustain relief absent statutory authorization. |
Key Cases Cited
- Galliano, S.A. v. Stallion, Inc., 15 N.Y.3d 75 (N.Y. 2010) (recognition act purposes; enforcement of foreign judgments)
- China Trade & Dev. Corp. v. M.V. Choong Yong, 837 F.2d 33 (2d Cir. 1987) (threshold considerations for antienforcement relief)
- Dow Jones & Co. v. Harrods, Ltd., 346 F.3d 357 (2d Cir. 2003) (declaratory relief standards; anti-foreign-suit context not controlling)
- Basic v. Fitzroy Eng’g, Ltd., 949 F. Supp. 1333 (N.D. Ill. 1996) (DJA usage; alternative remedies for judgment-debtors)
- Jota v. Texaco, Inc., 157 F.3d 153 (2d Cir. 1998) (background of Lago Agrio litigation and forum considerations)
- Ackermann v. Levine, 788 F.2d 830 (2d Cir. 1986) (burden-shifting in recognition nonrecognition analysis)