In Ungar v. Palestine Liberation Org., No. 09-1778, the First Circuit decided a case involving an action brought by the estate of plaintiffs against the Palestine Liberation Organization and the Palestinian Authority for damages under the Anti-Terrorism Act for the killing of the plaintiffs in Israel by Hamas. In addressing the question of whether there was a categorical rule that a party whose strategic choices lead to the entry of a default judgment is precluded from later obtaining relief from that judgment under Rule 60(b). In reversing the district court's judgment that precedent required it to apply a categorical bar in denying defendant's motion to vacate the default judgment, the court held that no such categorical bar applies.
Cossaboon v. Maine Med. Ctr., No. 09-1550, involved a plaintiff's medical malpractice action alleging that defendant's employee's breach of standard of care caused injuries to one of her newborn twins. In affirming district court's dismissal of the actio nfor lack of personal jurisdiction, the court held that viewing defendant's contacts in the aggregate, defendant has not deliberately established continuous and systematic contacts with New Hampshire such that it should reasonably anticipate being subject to suit in New Hampshire courts.