article thumbnail

Anti-enforcement injunction granted by the New Zealand court

Conflict of Laws

It later dropped the claim, presumably due to a recent English High Court decision ( W Nagel (a firm) v Chaim Pluczenik [2022] EWHC 1714) concluding that the tort of abuse of process does not extend to foreign proceedings (at [96]). Kea alleges that the US default judgment is based on fabricated claims intended to defraud Kea.

Court 52
article thumbnail

Choice of Law in the American Courts in 2023

Conflict of Laws

Meanwhile the Fifth Circuit enforced a forum selection clause in an insurance contract choosing British Virgin Island courts despite evidence that the claims stood little chance in those courts. Extraterritoriality The Supreme Court decided two important extraterritoriality cases.

Laws 73