Patton Boggs, LLP v. Chevron Corporation
401 U.S. App. D.C. 263
| D.C. Cir. | 2012Background
- Patton Boggs represents Ecuadorian Plaintiffs in ongoing § 1782 proceedings aiding foreign litigation against Chevron.
- Chevron sent a disqualification threat letter based on Breaux Lott’s prior Chevron representation, prompting Patton Boggs to seek declaratory relief in D.C. federal court.
- District court dismissed Patton Boggs’ declaratory judgment claim as premature and declined jurisdiction; also denied leave to amend to plead a tortious interference claim under Restatement § 766.
- Patton Boggs filed a second, duplicate complaint asserting tortious interference claims in the same action; district court dismissed for lack of viable pleadings and preclusion.
- Patton Boggs appealed all district court orders: denial of declaratory judgment, denial of amendment, and dismissal of the new complaint.
- The court of appeals affirms, holding that the district court appropriately exercised discretion and that the new § 766 claim was not adequately pleaded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion on declaratory relief | Patton Boggs asserts universal disqualification relief is warranted | Chevron argues ripeness and practical complexities require not exercising jurisdiction | Yes; district court did not abuse discretion in declining jurisdiction |
| Whether § 766A claim was properly pleaded | Patton Boggs attempted to plead breach-of-contract interference | Chevron contends pleadings show only a breach-oriented theory not plausible | No; § 766A claim inadequately pleaded and improperly raised belatedly |
| Whether new complaint with § 766 theory was viable | Patton Boggs seeks damages for intentional procurement of breach | Defendants lack specificity on breach and responsible actors | No; complaint vague and fails to allege plausible scenario of intentional procurement |
| Whether the duplicate suit and preclusion affect appeal | Patton Boggs argues against preclusion and for reconsideration | Chevron contends duplicate filing was improper | Affirmed; district court properly dismissed duplicate claims and preclusion defenses upheld |
Key Cases Cited
- Wilton v. Seven Falls Co., 515 U.S. 277 (1995) (declaratory judgments have discretion-based, practical considerations)
- Chevron Corp. v. Donziger, 768 F. Supp. 2d 581 (S.D.N.Y. 2011) (underlying environmental dispute and related litigation)
- Ciralsky v. CIA, 355 F.3d 661 (D.C. Cir. 2004) (abuse of discretion standards for new-claims under Rule 59(e))
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must show plausible entitlement to relief)
- Jones v. Horne, 634 F.3d 588 (D.C. Cir. 2011) (plausibility standard for complaint sufficiency)
- Barefoot Architect, Inc. v. Bunge, 632 F.3d 822 (3d Cir. 2011) (tortious interference standards—bearing on injury theory)
- Emirates v. 281 F.3d 1287, 281 F.3d 1287 (D.C. Cir. 2002) ( Restatement § 766A pleading framework)
- In re Korean Air Lines Disaster, 932 F.2d 1475 (D.C. Cir. 1991) (choice of law considerations in tort claims)