Professor Dodge Cited in Venezuela Act of State Case

On Jan. 13, the District Court for the District of Connecticut cited Professor William S. Dodge. The decision involved an attempt to substitute counsel for the Venezuelan oil company PDVSA to defend an action trying to seize $40 million from a brokerage account in Connecticut. The court held that the act of state doctrine did not require the court to recognize Venezuela’s decision as a shareholder, rather than the decision of PDVSA’s management, as to who should represent the company in the U.S. action. The court cited Dodge’s 2015 article International Comity in American Law with respect to the comity foundations of the act of state doctrine.

Professor Dodge is Martin Luther King Jr. Professor of Law and John D. Ayer Chair in Business Law at UC Davis School of Law. He is a leading expert on international law, international transactions, and international dispute resolution, who served as Counselor on International Law to the Legal Adviser at the U.S. Department of State from 2011-12 and as a reporter for the American Law Institute’s Restatement (Fourth) of Foreign Relations Law from 2012-18. Professor Dodge is a co-author of Transnational Business Problems and Transnational Litigation in a Nutshell, and a co-editor of International Law in the U.S. Supreme Court: Continuity and Change, which won the American Society of International Law’s 2012 certificate of merit. He has authored more than 60 other publications in books and law reviews.

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