Njsc Naftogaz of Ukraine v. Russian Federation

District Court, District of Columbia·Decided July 17, 2026·No. Civil Action No. 2023-1828·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NJSC NAFTOGAZ OF UKRAINE, et al., Petitioners, Civ. A. No. 23-1828 (JDB)

v.

THE RUSSIAN FEDERATION, Respondent.

MEMORANDUM OPINION & ORDER Nearly a decade ago, several Ukrainian companies (collectively, “NJSC Naftogaz of Ukraine” or “petitioners”) initiated arbitration against the Russian Federation, seeking compensation for Russia’s expropriation of their investments in Crimea. The arbitration tribunal issued the Final Award, awarding petitioners over $4.2 billion in compensation. Russia has subsequently sought to set aside the Final Award in The Hague Court of Appeal (“Hague Court”) and that court’s decision on Russia’s appeal remains pending. Meanwhile, NJSC Naftogaz of Ukraine petitions this Court to enforce the Final Award under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“New York Convention”).

Russia moved to dismiss the enforcement proceedings in this Court for lack of jurisdiction.

On the parties’ joint request, this Court originally stayed this action until April 1, 2026, pending the Hague Court’s decision. Now that date has passed, and Russia has moved to renew the stay until the Hague Court decides the validity of the Final Award and the U.S. Supreme Court reaches a decision on two certiorari petitions that concern the arbitration exception to sovereign immunity under the Foreign Sovereign Immunities Act (“FSIA”). Petitioners oppose a renewed stay. Ultimately, this Court finds that judicial economy favors an expeditious resolution of this dispute

and the balance of potential hardships from a continued stay tips in petitioners’ favor. Accordingly, this Court denies Russia’s motion for a renewed stay.

BACKGROUND

This dispute dates back nearly a decade to an arbitration initiated by petitioners against the Russian Federation under the Russia-Ukraine bilateral investment treaty (the “BIT”). Opp’n to Renewed Mot. to Stay (“Pet’rs’ Opp’n”) [ECF No. 39] at 3. Petitioners are Ukrainian oil and gas companies and were the largest operators in natural gas production, transportation, and distribution in Crimea. Id. After the Russian Federation seized control of Ukraine’s Crimean Peninsula, and with it petitioners’ investments in Crimea, petitioners initiated arbitration “seeking compensation for Russia’s unlawful expropriation of their investments.” Id.

The arbitration tribunal initially issued a Partial Award, finding that the tribunal had jurisdiction over petitioners’ claims and Russia was liable, clearing a path for the tribunal to issue the subsequent Final Award. Petition to Confirm [ECF No. 1] ¶ 3. Thereafter, Russia sought to set aside the Partial Award in the Hague Court. Renewed Mot. to Stay (“Resp’t’s Mot.”) [ECF No. 36-1] at 3. The Hague Court annulled the Partial Award in part but only “to the extent that the arbitral tribunal ruled that it has jurisdiction to assess all claims, since it has jurisdiction only to rule on investments made on or after January 1, 1992.” Id. Russia subsequently appealed the Hague Court’s judgment regarding the Partial Award to the Supreme Court of the Netherlands and that Court dismissed Russia’s appeal.1 Id. at 4.

1 In dismissing Russia’s appeal of the Partial Award, the Supreme Court of the Netherlands found that the Hague Court’s annulment of the Partial Award only dismissed the tribunal’s ruling “that it had jurisdiction to assess all claims,” instead of properly limiting its jurisdiction to claims regarding investments made on or after January 1, 1992. Resp’t’s Mot. at 4. The Supreme Court of the Netherlands instructed that the tribunal must determine which investments were made on or after January 1, 1992, and it was not up to a court of appeals to do so. Id.

In April 2023, the tribunal issued a Final Award, finding that all petitioners’ investments were made after 1992 and awarding over $4.2 billion in compensation. Id. Then, Russia brought an action to set aside the Final Award in the Hague Court, which remains ongoing. Id. The Hague Court was expected to reach a decision on the validity of the award on July 14, 2026, but “is free to extend the deadline.” Id.

Meanwhile, in June 2023, petitioners filed in this Court to confirm the Final Award pursuant to the New York Convention, which Russia subsequently moved to dismiss for lack of jurisdiction under the FSIA. Id. at 5. After the Supreme Court of the Netherlands’ ruling on the Partial Award, the parties proposed to stay this action until April 1, 2026. Joint Status Report [ECF No. 32] at 1, 5. This Court granted the stay. Order [ECF No. 33]. After the stay expired, Russia renewed its motion to stay this case pending resolution of the proceedings before the Hague Court and U.S. Supreme Court. Resp’t’s Mot. at 17.

In arguing for a renewed stay, Russia contends that its action to nullify the Final Award in the Hague Court supports a stay because the issue may be moot if the Hague Court sets aside the award. Id. at 11. Moreover, in the present action, Russia has raised the argument that the arbitration exception to the FSIA does not provide jurisdiction and that the existence of an arbitration agreement between Russia and petitioners must be determined at the jurisdiction stage—the same issue raised in both Russia’s certiorari petition in Russian Federation v. Stabil LLC, No. 25-1093 (Mar. 13, 2026), appealing Stabil LLC v. Russian Federation, 167 F.4th 506 (D.C. Cir. 2026),2 and Spain’s certiorari petition in Kingdom of Spain v. Blasket Renewable

2 The D.C. Circuit consolidated Stabil LLC v. Russian Federation, Civ. A. No. 22-00983, 2024 WL 5093202 (D.D.C. Dec. 12, 2024), and JSC DTEK Krymenergo v. Russian Federation, Civ. A. No. 23-03330, 2025 WL 1148347 (D.D.C. Apr. 17, 2025), for argument and wrote a single opinion finding the arbitration exception to the FSIA applied and affirming the denial of Russia’s motion to dismiss for lack of subject matter jurisdiction. Stabil LLC v. Russian Fed’n, 167 F.4th 506 (D.C. Cir. 2026).

Investments, LLC, No. 24-1130 (May 1, 2025), appealing NextEra Energy Global Holdings v. Kingdom of Spain, 112 F.4th 1088 (D.C. Cir. 2024). Resp’t’s Mot. at 5-6. Since Russia filed its motion to stay and reply with this Court, the U.S. Supreme Court denied both the Stabil and Blasket certiorari petitions. Russian Fed’n v. Stabil LLC, No. 25-1093, 2026 WL 1855103 (U.S. June 29, 2026); Spain v. Blasket Investments LLC, No. 24-1130, 2026 WL 1855038 (U.S. June 29, 2026).

In response, petitioners filed their opposition to Russia’s renewed motion to stay. Pet’rs’

Opp’n at 1. Petitioners disagree with Russia’s arguments in favor of a stay, asserting that the Hague Court proceedings “have no bearing on this Court’s jurisdiction” and the certiorari petitions “do not relieve this Court from its obligation to apply binding precedent.” Id. at 2 (citation modified). Further, petitioners assert that they originally agreed to “stay this action solely due to resource constraints resulting from Respondent’s ongoing invasion of Ukraine, which compelled petitioners to prioritize recognition and enforcement proceedings in other jurisdictions,” and that the prior agreement does not support a renewed stay. Id. at 6 (citation modified).

With briefing from both parties, the renewed motion to stay is now ripe for resolution.

LEGAL STANDARD

“[D]istrict courts have the inherent authority to manage their dockets and courtrooms with a view toward the efficient and expedient resolution of cases,” Dietz v. Bouldin, 579 U.S. 40, 47 (2016), including the broad discretion to stay a case, LLC SPS Stileks v. Republic of Moldova, 985 F.3d 871, 880 (D.C. Cir. 2021).

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