Waldman v. Palestine Liberation Organization

In Waldman v. Palestine Liberation Organization, the Second Circuit overturned a $655.5 million judgment against the Palestinian government. It concluded that the US District Court for the Southern District of New York could not exercise general or specific jurisdiction over the Palestine Liberation Organization and the Palestinian Authority, in a case involving overseas terrorist attacks that injured US citizens. It also rejected an argument that, for personal jurisdiction purposes, the Due Process Clause of the Fifth Amendment should be construed more broadly than the similar clause in the Fourteenth Amendment. In the process, the Waldman court may have elided an important distinction relating to federal service-of-process provisions that could have altered its analysis and conclusion.