Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

Bell appealed the vacatur of a default judgment as void in connection with the manufacture and marketing by Iran of a helicopter that resembled Bell's Jet Ranger 206 in appearance. The court concluded that Bell's interpretation of Rule 60(b)(4) was contrary to the court's precedent, as well as that of almost every other circuit court of appeals, all of which rejected a time limit that would bar Rule 60(b)(4) motions; because Iran never appeared in the district court proceeding resulting in the default judgment, the district court properly applied the traditional definition of voidness in granting Iran's Rule 60(b)(4) motion; and because Bell's evidence regarding the effect in the United States of Iran's commercial activities abroad was either too remote and attenuated to satisfy the direct effect requirement of the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1605(a)(2), or too speculative to be considered an effect at all, the district court did not err in ruling the commercial activity exception in the FSIA did not apply. Accordingly, the court affirmed the judgment of the district court. View "Bell Helicopter Textron, Inc., et al. v. Islamic Republic of Iran, et al." on Justia Law

OOIDA, a trade association, challenged the decision of the FMCSA to exempt commercial vehicle operators licensed in Canada or Mexico from certain statutory medical certification requirements applicable to drivers licensed in the United States. The FMCSA claimed that applying these requirements would violate existing executive agreements between those two countries and the United States. The court agreed with the government that absent some clear and overt indication from Congress, the court would not construe a statue to abrogate existing international agreements even when the statute's text was not itself ambiguous. The court presumed that the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (the "Act"), Pub. L. No. 109-59, 119 Stat. 1144, was not intended to abrogate the executive agreements with Mexico and Canada and held that the FMCSA's implementing rules appropriately understood the medical certificate requirement to apply only to drivers based in the United States. The court rejected OOIDA's secondary argument and denied the petition for review. View "Owner-Operator Independent Drivers Ass'n, Inc. v. U.S. Dept. of Transp., et al." on Justia Law

Appellant, a Guantanamo detainee, appealed from a judgment of the district court denying his petition for a writ of habeas corpus. On appeal, appellant argued that the district court erred in not affording him protection due "medical personnel" under the First Geneva Convention. Because appellant had not established that he was "medical personnel" as defined by the Geneva Conventions, and because all other issues have been determined in the previous proceedings, the court affirmed the judgment of the district court denying the petition for writ of habeas corpus. View "Al-Warafi v. Obama" on Justia Law

Plaintiffs, descendants of the Herzog Collection's owner, claimed that following World War II the Hungarian government entered into bailment agreements with them to retain possession of the Collection and later breached those agreements by refusing to return the artwork. Hungary appealed the district court's partial denial of its motion to dismiss. Plaintiffs cross-appealed the dismissal of their claims to eleven pieces of artwork on international comity grounds. The court found Hungary's arguments unpersuasive and affirmed the district court's partial denial of its motion to dismiss. However, because the court agreed with plaintiffs that the district court prematurely dismissed several of their claims on international comity grounds, the court reversed that portion of the decision. View "De Csepel, et al. v. Republic of Hungary, et al." on Justia Law

Plaintiffs brought civil claims against the sitting president of Sri Lanka under the Torture Victim Protection Act (TVPA), 28 U.S.C. 1350. On appeal, plaintiffs contended that the president was not immune from civil suit under the TVPA. Because, as a consequence of the State Department's suggestion of immunity, the president was entitled to head of state immunity under the common law while he remained in office, and because the TVPA did not abrogate that common law immunity, the court affirmed the judgment of the district court dismissing the complaint. View "Manoharan, et al v. Rajapaksa" on Justia Law

Peter Knowland sued Syria, Libya, and a number of Syrian and Libyan individuals and organizations for sponsoring and supporting the terrorist attacks on international flight terminals in Rome and Vienna on December 27, 1985. Knowland was injured in the Vienna attack. The district court dismissed the case as untimely, and Knowland's legal representative appealed. Because Knowland filed suit after the statute of limitations had run pursuant to the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1605A, his only hope of obtaining judicial relief depended on his ability to invoke the "related action" provision. Knowland argued that his suit was related to Estate of Buonocore v. Great Socialist People's Libyan Arab Jamahiriya, a suit against many of the same defendants for their alleged support of the Rome attack. The court concluded that the Vienna and Rome attacks constituted the same incident and thus Buonocore put defendants on notice that they could be liable for the Vienna attack. Accordingly, the court reversed and remanded. View "Beneden v. Al-Sanusi, et al" on Justia Law

Appellant alleged that the District of Columbia violated rights conferred upon him by Article 36(1)(b) of the Vienna Convention on Consular Relations, Apr. 24, 1963, 21 U.S.T. 77, 101, 596 U.N.T.S. 261. Appellant is a national of Jamaica and currently incarcerated in a federal penitentiary. Assuming without deciding that Article 36(1)(b) conferred individually enforceable rights under 42 U.S.C. 1983, the court concluded that appellant's suit was untimely. Accordingly, the court affirmed the district court's grant of summary judgment to the District of Columbia. View "Earle v. District of Columbia" on Justia Law

This case arose when some Ecuadorian citizens sued Chevron in an Ecuador court, alleging that Chevron was responsible for environmental damage there. As the proceedings in Ecuador unfolded, Chevron sued the Ecuadorian plaintiffs and their attorneys in the U.S. District Court for the Southern District of New York, claiming that the Ecuadorian plaintiffs and their attorneys had committed fraud in the proceedings in Ecuador. As part of the New York litigation, Chevron subpoenaed documents from the Weinberg Group and the subpoena was issued from the U.S. District Court for the District of Columbia. The Weinberg Group asserted the attorney-client and work product privileges over some of the documents responsive to the subpoena. Chevron moved to compel production of those documents in the D.C. district court. The D.C. district court found that the crime-fraud exception applied and granted Chevron's motion to compel, relying almost entirely on a decision in favor of Chevron by the New York district court in the underlying fraud investigation. The court concluded that, given that the D.C. district court relied on the decision of the New York district court and that the New York district court's decision was subsequently reversed by the Second Circuit, the court must vacate the D.C. district court's decision and remand. View "Chevron Corp. v. Weinberg Group" on Justia Law

Plaintiff filed a breach of contract action seeking over $12 million from the Royal Family Al-Saud and sixteen of its members (collectively, defendants) for failing to pay him for artwork he alleged they commissioned. Plaintiff had designed 29 sculptures for the Royal Family in 2006 and 2007. Defendants kept the sculptures but never paid plaintiff for any of them. Plaintiff attempted to serve process on defendants by mailing a copy of the summons and complaint to the Royal Embassy of Saudi Arabia, where plaintiff ordinarily communicated with defendants in past instances, but the Embassy refused to accept the first class mailing. The district court dismissed the pro se complaint for failure to prosecute under Local Civil Rule 83.23 because plaintiff failed to serve process on defendants pursuant to FRCP 4(f). The court held that, viewing all of the circumstances - the reasonable probability that plaintiff could obtain service on at least one of the defendants, plaintiff's dogged attempts to effect service of process and the district court's failure to provide "a form of notice sufficiently understandable to one in [plaintiff's] circumstances fairly to apprise him of what is required" to serve process, and to provide notice of the consequences of failing to serve process - the district court abused its discretion in dismissing the complaint. Accordingly, the court reversed the judgment. View " Angellino v. Royal Family Al-Saud, et al." on Justia Law

GSS Group brought this action to confirm a foreign arbitration award against the Port Authority of Liberia. The district court dismissed the petition for lack of personal jurisdiction after concluding that the Port Authority did not have sufficient contacts with the United States. The court concluded that the Port Authority claimed to be an independent juridical entity in its motion to dismiss, and GSS Group failed to contest that characterization. GSS Group's omission left in tact the Bancec presumption, First National City Bank v. Banco Para el Comercio Exterior de Cuba, which, under TMR Energy v. State Property Fund of Ukraine, guaranteed the Port Authority treatment as a separate "person" entitled to due process protection. That protection included the right to assert a minimum contacts defense. GSS Group had not identified any connection between the Port Authority and the United States and conceded that none existed. Therefore, the district court correctly dismissed the petition for lack of personal jurisdiction. View "GSS Group Ltd v. National Port Authority" on Justia Law