Jump to Navigation
Jump to Content

Chevron Corp. v. Donziger

ELR Citation: 46 ELR 20136
Nos. 14-0826(L), -0832(C), (2d Cir., 08/08/2016)

The Second Circuit affirmed a district court decision holding that an $8.646 billion judgment granted by an Ecuadorian court for pollution in the Amazon was procured by bribery, coercion, and fraud and enjoining an attorney and two of his Ecuadorian clients from seeking to enforce the judgment in the United States. The underlying case concerned environmental damage stemming from oil exploration in Ecuador's Lago Agrio region in the 1960s-1990s. The attorney appealed the U.S. injunction, principally on grounds of Article III standing, international comity, judicial estoppel, lack of legal authority for the granting of equitable relief, and/or lack of personal jurisdiction. But given the absence of challenges to the district court's factual findings, the express disclaimers by the Ecuadorian appellate courts of their own jurisdiction to "hear and resolve" the charges of corruption, and the district court's confinement of its injunction to a grant of in personam relief against the three defendants-appellants without disturbing the Ecuadorian judgment, the court found no basis for dismissal or reversal.