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4th Circuit Haikus: Civil Procedure Update

4th Circuit Haikus are back with key appellate decisions on civil procedure issues, condensed to the size of a haiku poem:


Forum selection

In Seoul isn’t convenient.

Here, “shall” means “may be.”

 – BAE Sys. Tech. Solution & Servs. v. Republic of Korea (Mar. 5, 2018)


If you’re banking on

Fee-shifting, better watch out

For intervenors.

– Brat v. Personhubballah (Feb. 26, 2018)


Process service on

Statutory agents won’t

Start removal clocks.

– Elliott v. Am. States Ins. Co. (Feb. 20, 2018)



Class actions are efficient

And (usually) fair.

– Campbell v. Boston Sci. Corp. (Feb. 5, 2018)


When you draft contracts,

Check if your forum hosts a

Federal courthouse.

– Bartels v. Saber Healthcare Grp. LLC (Jan. 22, 2018)


CAFA removal

Is not for additional


– Jackson v. Home Depot USA (Jan. 22, 2018)


If you sue Sudan,

Service on its embassy

Is a non-starter.

– Kumar v. Republic of Sudan (Jan. 18, 2018)