Paul Mollica's Federal Courts Blog

Neither Fed. R. Civ. P. 4(f) Nor Hague Service Convention Authorize International Service of Process by E-Mail, Holds Second Circuit

In Smart Study Co., LTD v. Shenzhenshixindajixieyouxiangongsi, No. 24-313 (2d Cir. Dec. 18, 2025), the Second Circuit holds in a matter of first impression that e-mail service on a foreign defendant violates the Hague Service Convention and cannot be supported by Fed. R. Civ. P. 4(f). The Convention on Service Abroad of Judicial and Extrajudicial…

by pwmollica1961 December 18, 2025

Concurring Seventh Circuit Judge Urges Reconsideration of Plain-Error Review Under Fed. R. Crim. P. 29

In United States v. Robinson, No. 24-2310 (7th Cir. Dec. 15, 2025), the Seventh Circuit reverses in part a conviction for bank fraud on sufficiency-of-the-evidence grounds, while a concurring judge argues that a change in Fed. R. Crim. P. 29 warrants reconsideration of the plain-error standard to challenges raised for the first time on appeal.…

by pwmollica1961 December 16, 2025

“Consensual Relationship Exception” Did Not Extend Jurisdiction of Tribal Court Over Nonmember Spouse in Divorce Case, Holds Eighth Circuit

In a case of first impression, the Eighth Circuit in Tix v. Tix, No. 24-3487 (8th Cir. Dec. 12, 2025) rejects Tribal Court jurisdiction over a nonmember spouse in a divorce case. “In September 2008, Robert William Tix, a member of the Prairie Island Mdewakanton Dakota Indian Community (the ‘Community’), married Kristin Ann McGowan [‘McGowen’],…

by pwmollica1961 December 12, 2025December 12, 2025

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