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Bridgeway Corp. v. Citibank

United States Court of Appeals for the Second Circuit
201 F.3d 134 (2000)


In 1995, the Supreme Court of Liberia entered a monetary judgment against Citibank (defendant) and in favor of Bridgeway Corporation (plaintiff), a Liberian company. In the 1980s and 1990s, Liberia was beset by official corruption and civil war. In 1994 and 1996, statutorily required annual United States Department of State "Country Reports," written by the department's area specialists, noted the Liberian judiciary's inefficiency and corruption. Bridgeway sued in a New York court to enforce the Liberian court's judgment against Citibank, and Citibank removed the case to federal district court. Citibank introduced the Country Reports, among other evidence, to show the Liberian judicial system's unfairness. The district court found that Liberian courts were unlikely to dispense impartial justice and granted summary judgment in Citibank's favor. Bridgeway appealed to the United States Court of Appeals for the Second Circuit, arguing the Country Reports were inadmissible because their authors noted the difficulty of obtaining reliable information under contemporary Liberian conditions.

Rule of Law


Holding and Reasoning (Calabresi, J.)

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