CC/Devas (Mauritius) Limited v. Antrix Corp. Ltd.
Petitioner CC/Devas (Mauritius) Limited · Respondent Antrix Corp. Ltd.
- Reporter
- 605 U.S. ___ (2025)
- From
- United States Court of Appeals for the Ninth Circuit
- How it got here
- writ of <i>certiorari</i>
Must plaintiffs prove minimum contacts before federal courts may assert personal jurisdiction over foreign states sued under the Foreign Sovereign Immunities Act?
Question before the CourtWhat happened
This case involves an agreement between two Indian corporations, Devas Multimedia Private Ltd. and Antrix Corp. Ltd. After a dispute arose, Devas obtained an arbitration award from the International Chamber of Commerce against Antrix. Devas then sought to confirm this award in a U.S. district court. Antrix challenged the court’s personal jurisdiction, but the district court confirmed the award, concluding that a minimum contacts analysis was unnecessary under the Foreign Sovereign Immunities Act (FSIA). Antrix appealed the confirmation order, arguing that the district court erred in exercising personal jurisdiction without conducting a minimum contacts analysis. Meanwhile, a group of intervenors, including CC/Devas (Mauritius) Ltd. and others, moved to register the judgment in the Eastern District of Virginia. Both Antrix and Devas challenged this registration order. The U.S. Court of Appeals reversed, concluding that the plaintiff must prove minimum contacts, and its failure to do so meant it could not exercise personal jurisdiction over Antrix.
The holding
Personal jurisdiction exists under the Foreign Sovereign Immunities Act (FSIA) when a statutory immunity exception applies and the foreign defendant has been properly served; the statute does not impose an additional requirement of showing "minimum contacts" under the Due Process Clause. Justice Samuel Alito authored the unanimous opinion of the Court. The FSIA provides that a federal court has personal jurisdiction over a foreign state if two express conditions are met: the court has subject-matter jurisdiction through one of the FSIA’s exceptions to immunity, and the foreign sovereign has been served in accordance with the statute’s rules. These two requirements are sufficient and exhaustive: once both are satisfied, personal jurisdiction “shall exist.” The statute does not mention “minimum contacts,” a test developed in general personal jurisdiction doctrine. Reading an unwritten minimum-contacts requirement into the jurisdictional provision would contradict the statutory text and undermine the structure of the FSIA, which was designed to be a comprehensive and predictable framework for assessing when foreign sovereigns can be sued in U.S. courts. Minimum contacts are not needed apart from the contacts already built into the FSIA’s immunity exceptions themselves. Some exceptions, such as for commercial activity with effects in the United States, inherently require significant U.S.-related conduct and may by themselves satisfy due process standards. But that satisfaction arises from the statutory design, not because §1330(b) of the FSIA incorporates constitutional due process standards.
Argued by
- Aaron M. Streett for the Petitioner in No. 24-17
- Matthew D. McGill for the Petitioners in No. 23-1201
- Sarah M. Harris for the United States, as amicus curiae, supporting the Petitioners
- Carter G. Phillips for the Respondents
Case path
- Oct 4, 2024 granted
- Mar 3, 2025 argued
- Jun 5, 2025 decided