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Celestin v. Caribbean Air Mail, Inc.

30 F.4th 133 (2022)

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Celestin v. Caribbean Air Mail, Inc.

United States Court of Appeals for the Second Circuit
30 F.4th 133 (2022)

Facts

Odilon Celestin and others (plaintiffs) sued Caribbean Air Mail, Inc. (defendant), other multinational telecommunications entities (defendants), and the government of Haiti (defendant) in United States federal district court. The complaint alleged that Haitian government officials had conspired with the entities to raise telecommunications prices in violation of United States antitrust law. The district court dismissed the complaint, ruling that the claims were barred by the act-of-state doctrine because they would involve the court judging the propriety of acts by the Haitian government. Celestin and others appealed the dismissal to the United States Court of Appeals for the Second Circuit.

Rule of Law

Issue

Holding and Reasoning (Park, J.)

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