Bridgeway Corp. v. Citibank

Bridgeway (plaintiff) sought to enforce a 1995 Liberian court judgment against Citibank (defendant) in U.S. federal court; Citibank countered with State Department "Country Reports" describing corruption and inefficiency in Liberia's judiciary during its civil-war era, and the district court relied on these reports to find Liberian courts unlikely to dispense impartial justice, granting Citibank summary judgment. Bridgeway appealed, arguing the reports were inadmissible because their own authors acknowledged the difficulty of obtaining reliable information in contemporary Liberia.