Let France Decide

Candel & Partners SAS v. ExxonMobil Corporation tested how far a Section 1782 subpoena can reach when the target lacks a meaningful connection to the foreign case. Candel wanted U.S. discovery for a French proceeding against a former ExxonMobil subsidiary, but the district court quashed the subpoena, and the Fifth Circuit affirmed.

The Court accepted the district court’s assessment of the Intel factors, under which that court (a) found the French tribunal capable of ordering its own discovery, (b) concluded that Candel was trying to evade “foreign proof-gathering restrictions,” and (c) found the request too broad. No. 25-20366 (July 23, 2026).