U.S. Supreme Court,
Civil Litigation
Apr. 4, 2015
Preventing US claims by suing abroad?
In cases involving private international law, U.S. courts should apply U.S. res judicata law.
Imagine that a Frenchman ("Francois") contacts a fellow business-owner in California ("Cal"), and convinces Cal to buy into Francois' company. Cal buys in, only to have the company go belly-up before the ink is dry. While it's drying, Francois sues Cal in France for alleged breaches. Cal sues in California under California law, alleging that Francois fraudulently induced him to make the deal. Francois removes Cal's suit to federal court and argues that France is the proper forum for the ...
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