No. 21-401October Term 2021Decided Jun 13, 2022
ZF Automotive U. S., Inc. v. Luxshare, Ltd.
The key question is whether U.S. discovery help is available for private arbitration proceedings abroad.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jun 13, 2022
- What it's about
This case asked whether parties in private arbitration proceedings overseas can use a federal statute, 28 U.S.C. § 1782(a), to get discovery in U.S. courts for use in those arbitrations. The Supreme Court held that the statute applies only to governmental or intergovernmental tribunals, not private commercial arbitration panels.
Question presented
Whether 28 U.S.C. § 1782(a), which permits litigants to invoke the authority of United States courts to render assistance in gathering evidence for use in "a foreign or international tribunal," encompasses private commercial arbitral tribunals, as the U.S. Courts of Appeals for the Fourth and Sixth Circuits have held, or excludes such tribunals, as the U.S. Courts of Appeals for the Second, Fifth, and Seventh Circuits have held.
- Case path
United States Court of Appeals for the Sixth Circuit / Decision released Jun 13, 2022
- Area
Business and Regulation
Briefing
What it's about
The case asks whether a federal law, 28 U.S.C. § 1782(a), lets parties in private commercial arbitration overseas ask U.S. courts for evidence. The Supreme Court took the case to resolve a split among federal appeals courts on what counts as a "foreign or international tribunal" under that law.
Vote
The case is still pending, and oral argument has not yet been scheduled according to the case record provided. The parties disagree over whether § 1782(a) covers private commercial arbitration panels or only governmental or intergovernmental bodies.
Impact
The answer could affect how much evidence businesses can get from people or companies in the United States for use in overseas arbitration. For example, a company in a foreign contract dispute might try to use a U.S. court to obtain documents or testimony located here.
What's next
The next milestone is oral argument or another scheduling move from the Court. No decision window is available yet based on the record provided.
What is the core dispute in ZF Automotive U. S., Inc. v. Luxshare, Ltd.?
The justices are being asked whether § 1782(a) covers private commercial arbitration overseas. That determines whether parties can seek evidence through U.S. courts for those proceedings.
Why could this case matter for companies and other litigants?
It could change how easily parties in overseas arbitration obtain U.S.-based documents or testimony. That can shape costs, leverage, and access to proof in international business disputes.
What should readers watch for next in this case?
Watch for the Supreme Court to schedule oral argument or take another public step in the case. The record provided says no decision window is available yet.
Decision
What the Court decided
The key question is whether U.S. discovery help is available for private arbitration proceedings abroad.
Impact
The answer could affect how much evidence businesses can get from people or companies in the United States for use in overseas arbitration. For example, a company in a foreign contract dispute might try to use a U.S. court to obtain documents or testimony located here.
Not official Court text.
Opinion documents
Timing
Decided June 13, 2022
The Court released its decision on June 13, 2022 without hearing oral argument.
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 2, 2026
- Method
- Methodology
Primary materials11
Supreme Court docket 21-401
docket | Jul 25, 2026
Primary case document
Supreme Court document | Jul 25, 2026
CourtListener docket record
docket | Jul 25, 2026
Questions Presented
brief | May 25, 2026
opinion
opinion | Jun 13, 2022
Reply
brief | Oct 22, 2021
Petition
brief | Sep 10, 2021
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026