UNITED STATES 17 September 2026 Lao People’s Democratic Republic
United States Court of Appeals, Ninth Circuit, 17 September 2026, No. 25-2562, D.C. No. 1:22-cv-00011
(The Government of the Lao People’s Democratic Republic v. John K. Baldwin and Bridge Capital, LLC)
UNITED STATES 17 September 2026 Lao People’s Democratic Republic
A district court had held that it lacked jurisdiction to enforce awards against parties not named in the awards themselves, which parties Lao PDR alleged were alter egos of the named parties. The Court of Appeals reversed, finding that the district court had jurisdiction under the FAA 9 U.S.C. § 203, and should have evaluated the merits of Lao PDR’s alter ego theory.
The court discusses issues relating to the identity of the party against whom enforcement of the arbitral award is sought, including: piercing of the corporate veil, succession, assignment, State or State entity, group of companies, agent or principal, etc. For the related defenses to enforcement, see Art. V(1)(a).