BG Group PLC v. Republic of Argentina, 134 S. Ct. 1198 (Mar. 5, 2014)
This action arose from an investment by British company BG Group PLC (“BG”) in Argentina and under the protection of a treaty between the United Kingdom and Argentina. The treaty included a provision that required an aggrieved investor to submit their dispute to a local court in the country where the investment was made for a period of eighteen months prior to pursuing arbitration. BG invoked the treaty for Argentina’s alleged breach of a natural gas distribution contract. However, prior to exhausting the treaty’s local litigation requirement, BG proceeded to arbitration in Washington D.C.
Argentina argued that the arbitral panel lacked jurisdiction because BG had not complied with the local litigation requirement. The arbitral panel concluded that it had jurisdiction, finding, among other things, that Argentina’s conduct (such as enacting new laws that hindered recourse to its judiciary by investors in BG’s situation) had excused BG’s failure to comply with the local litigation requirement. The matter proceeded through arbitration where BG was awarded $185 million in damages.
Argentina turned to American courts to overturn the award, again advancing the argument that the arbitral panel lacked jurisdiction. The district court initially confirmed the award, but on appeal to the Circuit Court it was vacated. The Circuit Court held that the gateway issue of arbitrability at hand—whether BG was required to commence litigation before the local courts and wait eighteen months before it could commence arbitration—was for a court, and not the arbitral panel, to decide.