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Mobil and others v. Venezuela, Order of the United States Court of Appeal for the District of Columbia Circuit, April 7, 2026

7 Apr 2026
Venezuela Holdings, B.V., et al (case formerly known as Mobil Corporation, Venezuela Holdings, B.V., et al.) v. Bolivarian Republic of Venezuela, ICSID Case No. ARB/07/27
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Order of the United States Court of Appeal for the District of Columbia Circuit
Document Details:
LISTED PARTICIPANTS
Order of the United States Court of Appeal for the District of Columbia Circuit
Participants listed are for this document only and may not include all participants involved in the entire case. Always consult the original documents.
Claimant appointee
Respondent appointee
Tribunal/Panel chair
Arbitrator(s)
Sole Arbitrator
ICSID Annulment Committee president
ICSID Annulment Committee members
WTO Appellate Body members
WTO Appellate Body chair
Judges
Robert Leon Wilkins, Gregory George Katsas, Neomi Jehangir Rao
Claimant's counsel
Claimant's law firm
Respondent's counsel
Respondent's law firm
Other counsel
Claimant's expert
Claimant's expert firm
Respondent's expert
Respondent's expert firm
Claimant's witness
Respondent's witness
Other witnesses
Tribunal secretary
Tribunal assistant
Third-party funder
Entities
Venezuela Holdings B.V., Venezuela
Country
United States
Print reporter
Document Summary
Order of the United States Court of Appeal for the District of Columbia Circuit
This summary note is machine-generated. Always consult the original materials.

Procedural Posture

This document is an Order issued by the United States Court of Appeals for the District of Columbia Circuit, addressing a motion for summary affirmance in an action for the recognition and enforcement of an arbitral award rendered under the auspices of the International Centre for Settlement of Investment Disputes (ICSID). The appellant, the Bolivarian Republic of Venezuela, appealed the district court’s grant of summary judgment in favor of the appellees, seeking to resist enforcement of the underlying ICSID award.

Court's Analysis

The principal legal issue before the Court was whether the ICSID tribunal's decision to permit legal representation designated by the government of Nicolás Maduro, rather than that of Juan Guaidó, deprived Venezuela of due process or vitiated the tribunal's jurisdiction. Applying the full faith and credit mandate of 22 U.S.C. § 1650a, the Court relied on its binding precedent in Valores Mundiales, S.L. v. Bolivarian Republic of Venezuela. The Court held that the representation issue had been fully and fairly litigated before the ICSID tribunal and therefore could not be relitigated in enforcement proceedings, even when framed by the appellant as a jurisdictional defect.

Furthermore, the Court rejected Venezuela's arguments that enforcement was precluded by the United States government's prior recognition of the Guaidó regime. The Court also dismissed Venezuela's reliance on the act of state doctrine, noting that the appellant had failed to raise this issue before the district court and had therefore forfeited the argument.

Decision

The Court granted the motion for summary affirmance, concluding that the merits of the parties' positions were sufficiently clear to warrant summary action. The Clerk was directed to withhold the issuance of the mandate pending the resolution of any timely petition for rehearing or rehearing en banc.