A U.S. District Court has modified subpoenas issued by Blasket Renewable Investments, LLC against the Kingdom of Spain, impacting the way the company can pursue a $47 million judgment. The ruling, made by Judge John D. Bates on June 22, 2026, limits the scope of discovery related to Spain's national football team and federation in connection with the 2026 FIFA World Cup.
This decision is significant as it affects how entities can enforce foreign arbitral awards in the United States. It highlights the complexities involved when dealing with state entities and their instrumentalities, particularly in the context of international sports.
The case arose after Blasket Renewable Investments won a foreign arbitral award against Spain in 2025. Following this, the company sought to enforce the judgment by issuing subpoenas to various U.S.-based companies that provide services to Spain's national football team. These subpoenas aimed to gather information about financial transactions and agreements between these companies and the Spanish government.
The dispute centers around whether the subpoenas are overly burdensome and whether they seek information relevant to identifying attachable assets of the Kingdom of Spain. Spain argued that the subpoenas were excessive and harassed its football team and federation by demanding private financial information unrelated to the judgment enforcement.
In its ruling, the court found that Blasket had not provided sufficient evidence to support its claim that Spain's national football team and federation were alter egos of the state. Judge Bates noted, "Blasket has offered no evidence that Spain exercises sufficient control over its national football federation and team to render them alter egos of the state." This statement underscores the distinction between the sovereign state and its instrumentalities.
The court also pointed out that the subpoenas sought information that was largely irrelevant to identifying Spain's attachable property. Judge Bates stated, "The World Cup subpoenas impose an undue burden because they demand large swaths of documents irrelevant to discovering Spain’s attachable assets." As a result, the court granted Spain’s motion to modify the subpoenas.
This ruling has implications for future cases involving foreign sovereigns and the enforcement of judgments against them. It clarifies that while post-judgment discovery is generally permissive, it must still adhere to relevance standards. The court emphasized that judgment creditors must seek information that is directly relevant to identifying attachable assets.
Moving forward, this decision may influence how other entities approach post-judgment discovery against foreign states. It serves as a reminder that while the legal framework allows for extensive discovery, there are limits, particularly when dealing with government entities and their associated organizations.
As for what’s next, Blasket may modify its subpoenas to comply with the court's ruling. The court instructed Blasket to remove Spain’s national football federation and team from its definition of Spain in the subpoenas, as well as the Bank of Spain. This modification must align with the court’s previous orders, including a protective order issued earlier in the case.
Details were not available in the court filing regarding whether Blasket plans to appeal this decision or if there are related cases pending. However, the ruling sets a clear precedent for how post-judgment discovery will be handled in similar situations involving foreign governments.