ENI S.p.A v. Gulf LNG Energy, LLC, et al.

W het her, consist ent w it h t he Fou r t eent h Amendment of the United States Constitution and the Federal Arbitration Act, a state court may extend the claim preclusion doctrine to deprive a nonparty of its day in court and extinguish its contractual claims based on a prior arbitration award where the tribunal had no jurisdiction over the nonparty, its contracts, or its claims.

W het her, consist ent w it h t he Fou r t eent h Amendment of the United States Constitution and the due process limitations established by this Court, a state court may extend the claim preclusion doctrine to deprive a nonparty of its day in court and extinguish its contractual claims by finding an exception to nonparty preclusion based on corporate affiliation and overlapping rights and interests, where the nonparty’s rights and interests were not represented and its claims were not resolved in the prior action.