The plaintiffs rely on five opinions from other
circuits for the idea that the Four Princes’ alleged
involvement in a terrorist attack on a citizen of the United
States constitutes purposeful direction at this forum, “such
that [they] should reasonably anticipate being haled into
all addressed defendants who were primary participants in
Burger King, 471 U.S. at 474.
But those cases
Cir. 2005), the court exercised personal jurisdiction over
al Qaeda and Osama bin Laden for injuries arising out of the
bombing of our embassies in Kenya and Tanzania, reasoning
that their “decision to purposefully direct their terror at
the United States, and the fact that the plaintiffs’
injuries arose out of one of those terrorist activities,
should suffice to cause the defendants to ‘reasonably
anticipate being haled into’ an American court.”
(quoting Burger King, 471 U.S. at 474).
defendant in Morris v. Khadr, 415 F. Supp. 2d 1323 (D. Utah
2006), was an al Qaeda member who “actively participated in
and helped plan al Qaeda’s terrorist agenda--so much so, in
In Mwani v. bin Laden, 417 F.3d 1 (D.C.
Id. at 14
United States Court of Appeals for the Second Circuit: In Re Terrorist Attacks