Arabie v. CITGO Petroleum Corp.

89 So. 3d 307 (2012)

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Arabie v. CITGO Petroleum Corp.

Louisiana Supreme Court
89 So. 3d 307 (2012)

Facts

CITGO Petroleum Corporation (CITGO) (defendant) was incorporated in Delaware and had its principal place of business in Oklahoma and then in Texas. CITGO operated a large oil refinery in Louisiana, at which up to 1,800 employees and contractors worked. A significant spill occurred at CITGO’s Louisiana refinery, which CITGO admitted was caused by its negligence. Some of CITGO’s negligence occurred in Oklahoma or Texas, and some occurred in Louisiana. Craig Arabie and others (collectively, Arabie) (plaintiffs) sued CITGO for their spill-related injuries. The district court awarded compensatory and punitive damages. With respect to punitive damages, the district court applied Louisiana’s choice-of-law statutes in deciding that either Oklahoma or Texas law regarding punitive damages (which allowed such damages) governed, primarily because the court concluded that the injury-causing conduct mainly occurred in either Oklahoma or Texas and thus that CITGO was domiciled in Oklahoma or Texas. CITGO appealed, arguing that it was domiciled in Louisiana for punitive-damages purposes and thus that Louisiana law (which disfavored punitive damages) governed.

Rule of Law

Issue

Holding and Reasoning (Clark, J.)

Concurrence (Guidry, J.)

Concurrence/Dissent (Knoll, J.)

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