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ARTICLE · 07 FEBRUARY 2025

Arbitration In The Courts

Chaffetz Lindsey LLP
Chaffetz Lindsey LLP
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Chaffetz Lindsey LLP

Chaffetz Lindsey LLP

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New York appellate court holds that prior arbitration award precluded claim by party's affiliate under doctrine of res judicata...

United StatesLitigation, Mediation & Arbitration

New York appellate court holds that prior arbitration award precluded claim by party's affiliate under doctrine of res judicata:

Non-party to arbitration was precluded from bringing breach of contract claim when the same issue was or could have been adjudicated by a related party in a prior arbitration.

Gulf LNG Energy, LLC v. Eni S.p.A., 219 N.Y.S.3d 17 (1st Dep't Sep. 24, 2024).

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The doctrine of res judicata or claim preclusion prevents parties from relitigating claims that were or could have been raised in a prior action. U.S. courts have long applied this doctrine "with equal force" to claims brought in arbitration, thus barring parties from raising the same claim resolved in a prior arbitration in a subsequent court action. Gulf v. Eni S.p.A, is a reminder of two fundamental aspects of res judicata. First, non-parties in privity with the parties to a prior action may find themselves precluded from pursuing related claims that were or could have been

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