ENI S.p.A v. Gulf LNG Energy, LLC, et al.
Arbitration DueProcess Privacy JusticiabilityDoctri
Whether a state court may extend claim preclusion to deprive a nonparty of its claims based on a prior arbitration award without jurisdiction, and whether such extension violates due process
1. Whether, consistent with the Fourteenth Amendment of the United States Constitution and the Federal Arbitration Act, a state court may extend the claim preclusion doctrine to deprive a nonparty of its day in court and extinguish its contractual claims based on a prior arbitration award where the tribunal had no jurisdiction over the nonparty, its contracts, or its claims. 2. Whether, consistent with the Fourteenth Amendment of the United States Constitution and the due process limitations established by this Court, a state court may extend the claim preclusion doctrine to deprive a nonparty of its day in court and extinguish its contractual claims by finding an exception to nonparty preclusion based on corporate affiliation and overlapping rights and interests, where the nonparty’s rights and interests were not represented and its claims were not resolved in the prior action.