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Waldman v. Palestine Liberation Organization

835 F.3d 317 (2d Cir. 2016)

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Waldman v. Palestine Liberation Organization

United States Court of Appeals for the Second Circuit

835 F.3d 317 (2d Cir. 2016)

Facts

Eva Waldman and other family members of eleven people killed or wounded in terrorist attacks in Israel (collectively, plaintiffs) sued the Palestine Liberation Organization (PLO) and the Palestinian Authority (PA) (collectively, defendants) under the Anti-Terrorism Act (ATA). Waldman served the PLO and PA by delivering the complaint and summons to their chief representative, Hassan Abdel Rahman, at his home in Virginia. The PLO and PA contested the district court’s personal jurisdiction over them because Waldman’s claims lacked any nexus with the United States, and the PLO and PA had minimal presence there. The PA operated exclusively in Palestine, while the PLO operated globally as the PA’s diplomatic agent. Neither organization had systematic and continuous contacts with the United States. However, the district court found Waldman properly served the PLO and PA because the ATA provides for nationwide process service and venue, and concluded it had general personal jurisdiction over them. The jury awarded damages over $218 million, automatically tripled under the ATA to over $655 million. The PLO and PA appealed, contesting personal jurisdiction.

Rule of Law

Issue

Holding and Reasoning (Koeltl, J.)

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