On September 19, 2011, a federal appeals court reversed Southern District Judge Lewis Kaplan's preliminary injunction blocking worldwide enforcement of an $18 billion environmental judgment in Ecuador.

In its ruling, a three-judge Second Circuit panel vacated the injunction. Judges Rosemary Pooler, Richard Wesley and Gerard Lynch issued the summary order after expressing skepticism on Judge Kaplan's authority to issue the worldwide injunction. The judges said they would follow with a full opinion.