Yegiazaryan v. Smagin
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Yegiazaryan v. Smagin and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Yegiazaryan v. Smagin.
In Yegiazaryan v. Smagin, the Supreme Court addressed whether Smagin, a Russian resident, alleged a 'domestic injury' under the Racketeer Influenced and Corrupt Organizations Act (RICO) in his efforts to enforce a California judgment against Yegiazaryan. The Court affirmed the Ninth Circuit's context-specific approach, determining that Smagin's injury arose in the United States due to the racketeering activities aimed at frustrating the California judgment. The decision emphasizes a nuanced assessment of the circumstances surrounding the injury.
Holding
The single most important “bottom line” of what the Court decided in Yegiazaryan v. Smagin.
The Court held that a plaintiff alleges a domestic injury for purposes of § 1964(c) when the circumstances surrounding the injury indicate it arose in the United States.
Constitutional Concepts
These are the Constitution-related themes that appear in Yegiazaryan v. Smagin. Click a concept to see other cases that involve the same idea.
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Why Judicial Review is relevant to Yegiazaryan v. Smagin
The Court's decision involves interpreting the application of the RICO statute and determining the scope of 'domestic injury' under federal law.
Syllabus excerpt (verbatim)Held: A plaintiff alleges a domestic injury for purposes of § 1964(c) when the circumstances surrounding the injury indicate it arose in the United States.
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Why State–Federal Power is relevant to Yegiazaryan v. Smagin
The case involves the enforcement of a foreign arbitration award in a U.S. federal court, implicating the balance of state and federal judicial authority.
Syllabus excerpt (verbatim)Smagin, who lives in Russia, fled suit to confirm and enforce the award in the Central District of California pursuant to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards.
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Why Standing is relevant to Yegiazaryan v. Smagin
The Court's analysis of whether Smagin has alleged a 'domestic injury' under RICO relates to his standing to bring the suit.
Syllabus excerpt (verbatim)The Ninth Circuit instead applied a context-specific approach and concluded that Smagin had pleaded a domestic injury.
Key Quotes
Short excerpts from the syllabus in Yegiazaryan v. Smagin that support the summary and concepts above.
A plaintiff alleges a domestic injury for purposes of § 1964(c) when the circumstances surrounding the injury indicate it arose in the United States.
The domestic-injury inquiry is context specific and turns largely on the facts alleged in the complaint.
The alleged RICO scheme thwarted those rights, thereby undercutting the orders of the California District Court.
