United States First Circuit

In this case, defendants challenge the district court's exercise of personal jurisdiction over certain defendants, the denial of their motions to dismiss, and the entry of default judgment and a damages award against them as a sanction for discovery violations. The judgment of the district court is affirmed, where: 1) the conduct of defendants in fraudulently transferring assets out of Massachusetts was sufficient to establish personal jurisdiction, as such conduct was materially connected the forum state; 2) plaintiff's allegations sufficiently plead tortious interference with contractual relations under Massachusetts law; 3) given the severity of defendants' discovery violations, the district court acted well within its discretion in entering default judgment, a sanction that can play a "constructive role in maintaining the orderly and efficient administration of justice"; and 4) the district court did not abuse its discretion when it entered a damage award based on preexisting figures without an evidentiary hearing.

Appellate Information

• Decided 03/11/2015
• Published 03/11/2015

Judges

• Stahl

Court

• United States First Circuit

Counsel