United States First Circuit

In suit by heirs to deceased terrorist victims against defendant-attorney who represented them in claim against the State of Libya, alleging that the retainer agreements were void because defendant-attorney secured their consent by deceit, judgment for plaintiffs nullifying the retainer agreements and ordering restitution is affirmed, where: 1) a reasonable jury could have concluded that defendant misled plaintiffs into signing the retainer agreements; 2) defendant's misrepresentations constituted dolo (obtaining consent through deceit under Puerto Rico law); 3) the testifying heirs presented enough evidence for the jury to conclude that defendant deceived the non-testifying heirs into signing the retainer agreements; and 4) the district court's decision to omit defendant's proposed instruction on incidental dolo was not erroneous.

Appellate Information

• Decided 01/07/2013
• Published 01/07/2013

Judges

• HOWARD

Court

• United States First Circuit

Counsel