Aguinda v. Texaco

303 F.3d 470 (2002)

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Aguinda v. Texaco

United States Court of Appeals for the Second Circuit
303 F.3d 470 (2002)

Facts

A subsidiary of Texaco (defendant) maintained an oil-extraction operation in Ecuador. Residents of the area who were harmed by the pollution created by the operation (collectively, the residents) (plaintiffs) filed a class action in district court in New York, alleging a number of tort claims and seeking equitable relief. Texaco moved to dismiss the case on the basis of forum non conveniens. The district court ruled in favor of Texaco. The residents appealed, and the Court of Appeals for the Second Circuit reversed because the district court had not considered whether Ecuadorian courts could handle the litigation. On remand, the district court again dismissed the case on the grounds of forum non conveniens, finding that Ecuador was an adequate alternative forum. The residents again appealed to the Second Circuit, arguing that the district court’s dismissal was an abuse of discretion. The residents argued that the Ecuadorian courts were not an adequate alternative forum because an Ecuadorian law extinguished domestic jurisdiction over cases filed abroad, the courts did not allow class actions, and the courts were corrupt and not impartial.

Rule of Law

Issue

Holding and Reasoning (Leval, J.)

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