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Second Circuit – Foreign Sovereign Immunities Act: Creditincome Limited v. The Swiss Confederation
Daily Record Staff//August 4, 2026//
United States Court of Appeals for the Second Circuit
Foreign Sovereign Immunities Act — Commercial activity exception
Creditincome Limited v. The Swiss Confederation
25-2733
Judges Calabresi, Chin, and Merriam
Background: Following the merger of Credit Suisse with another Swiss bank, UBS, bondholders commenced an action claiming that Switzerland unlawfully ordered Credit Suisse to write their investments down to zero. The bondholders appealed from the dismissal of their claim.
Ruling: The Second Circuit affirmed. The court held that Switzerland’s brokering of the merger was not commercial in nature. Thus, the activity does not fall within the exception to the Foreign Sovereign Immunities Act.
John F. Bash, of Quinn Emanuel Urquhart & Sullivan, for the plaintiffs-appellants; Anitha Reddy, of Wachtell, Lipton, Rosen & Katz, for the defendant-appellee.
Case Digests
- Fourth Department – Separation of powers doctrine: Allard v. County of Steuben
- Second Circuit – Foreign Sovereign Immunities Act: Creditincome Limited v. The Swiss Confederation
- Fourth Department – Circumstantial evidence charge: People v. Coleman
- Second Circuit – Sentencing conditions: United States v. McCrone
- Fourth Department – Mental illness: People v. Williams
- Fourth Department – Sex Offender Registration Act: People v. Wallace
- Second Circuit – Failure to accommodate religion: Bergin v. N.Y. Unified Court System
- Second Circuit – Sentencing: United States v. DeJesus
- Fourth Department – Ineffective assistance of counsel: People v. Castaneda
- Fourth Department – Search warrant: People v. Anderson
- Fourth Department – Probable cause: People v. Asbury
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