Saint-Gobain Performance Plastics Europe v. Bolivarian Rep. of Venezuela, No. 21-7019 (D.C. Cir. 2022)
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Saint-Gobain Performance Plastics Europe sought compensation for the expropriation of its interests in a company in Venezuela. The district court granted Saint-Gobain summary judgment after determining it had properly served the Republic of Venezuela with court process pursuant to the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters.
The D.C. Circuit reversed. The Foreign Sovereign Immunities Act, 28 U.S.C. 1608, identifies four methods for serving a foreign state. The method at issue is “by delivery of a copy of the summons and complaint in accordance with an applicable international convention on service of judicial documents”; the Hague Convention is such an international agreement. Articles 2-6 of the Hague Convention require that a plaintiff request service from a Central Authority designated by the receiving state and receive a certificate of service from the Central Authority stating it has served the defendant by a method consistent with the state’s internal law. Venezuelan law requires lawsuits against the Republic to be served on the Attorney General, and the Attorney General was never served.
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