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Carteret Savings & Loan Assn. v. Jackson
United States Court of Appeals for the First Circuit
812 F.2d 36 (1st Cir. 1987)
The Jacksons (defendants) financed the purchase of a yacht by signing a promissory note and receiving a loan from Carteret Savings & Loan Association (Carteret) (plaintiff). The Jacksons defaulted on the promissory note, and Carteret sued in federal district court in Florida. The Jacksons served no pleading in the case, and Carteret obtained a default judgment. The yacht was sold in partial satisfaction of the judgment, and Carteret then sued the Jacksons in federal district court in Massachusetts to recover the remainder of the default judgment. In the Massachusetts action, the Jacksons attempted to assert counterclaims against Carteret for negligence, fraud, abuse of process, and unfair and deceptive business practices. However, the Massachusetts federal court ruled that such counterclaims were barred, as they should have been raised as compulsory counterclaims in the original action in Florida federal court. The Jacksons appeal this ruling, arguing that their counterclaims need not have been asserted in the Florida action as compulsory counterclaims because they did not enter any pleadings in the Florida action.
Rule of Law
Holding and Reasoning (Aldrich, J.)
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