CC/Devas (Mauritius) Ltd. v. Antrix Corp.

Devas Multimedia Private Ltd., an Indian company, signed a satellite-leasing agreement with Antrix Corp. Ltd., a company owned by the Republic of India. In 2011, the Indian Government determined it needed more satellite capacity, leading Antrix to terminate the contract under a force majeure clause. Devas initiated ICC arbitration, and in September 2015, the tribunal unanimously concluded Antrix had breached the contract and awarded Devas $562.5 million in damages plus interest. Devas petitioned the U.S. District Court for the Western District of Washington to confirm the award, which confirmed it and entered a $1.29 billion judgment. The Ninth Circuit reversed, holding that the FSIA requires a traditional minimum contacts analysis for personal jurisdiction. The Supreme Court granted certiorari, heard oral arguments on March 3, 2025, and issued its unanimous decision on June 5, 2025.

The Supreme Court held that personal jurisdiction exists under the FSIA when an immunity exception applies and service is proper. The FSIA does not require proof of "minimum contacts" beyond the contacts already required by the Act's enumerated exceptions to foreign sovereign immunity. Justice Samuel Alito delivered the unanimous opinion of the Court. The judgment of the Ninth Circuit was reversed, and the case was remanded for further proceedings consistent with the opinion. The Court left open whether minimum contacts are required under the Fifth Amendment's Due Process Clause.

Whether plaintiffs must prove minimum contacts before federal courts may assert personal jurisdiction over foreign states sued under the Foreign Sovereign Immunities Act. The core question was whether the FSIA's personal jurisdiction provision (§1330(b)) requires a traditional minimum contacts analysis in addition to an immunity exception and proper service.

The decision was a significant victory for parties seeking to enforce arbitral awards against foreign states in U.S. courts, reaffirming that FSIA jurisdiction is established through statutory exceptions and proper service rather than minimum contacts analysis. The ruling has substantial implications for international arbitration enforcement and post-judgment asset discovery. By leaving the constitutional question open, the Supreme Court created uncertainty for future cases, as the Ninth Circuit on remand must now address whether the Fifth Amendment independently requires minimum contacts. The case also highlighted tensions between U.S. arbitration enforcement and foreign sovereign immunity, with India having previously filed an amicus brief in the proceedings.