Case Explained: GOCE GLIGOROV v. NATION OF BRUNEI

Court: United States Court of Appeals for the District of Columbia Circuit Filed: 2026-08-07 The D.C. Circuit affirmed the District Court’s dismissal of Goce Gligorov’s civil RICO and tort claims against three corporate defendants for lack of personal jurisdiction. The court held that exercising personal jurisdiction over the foreign corporate defendants would violate the Fifth Amendment’s Due Process Clause because there was no reasonable nexus between the defendants and the United States. The court applied a “reasonableness” test, assuming without deciding that this standard governs federal-question cases under Rule 4(k)(2) following *Fuld v. Palestine Liberation Organization*. Under this framework, the court balanced the plaintiff’s interest in obtaining relief, the United States’ sovereign interest, and the burden on the defendants. The court found that Gligorov failed to establish a concrete interest in litigating in the U.S., as he is a non-resident Slovenian national with no significant business ties to the country other than speculative lost contracts. Furthermore, the court determined there was no meaningful U.S. sovereign interest in resolving this dispute, which involved alleged corruption and conspiracy among foreign officials and entities occurring almost exclusively overseas. Finally, the court concluded that the burden on the defendants was unreasonable given their scant connections to the United States; while one defendant operated hotels in California, the allegations of a conspiracy to harm Gligorov’s reputation were far outside the scope of its hotelier business, and the other two defendants had no U.S. presence at all. Regarding jurisdictional discovery, the court affirmed the District Court’s denial of Gligorov’s motion, ruling that his request constituted an impermissible “fishing expedition.” The court found Gligorov lacked a good-faith basis to believe further discovery would uncover facts establishing a reasonable nexus, as his pleadings contained no specific allegations connecting the defendants’ conduct to the United States in a way that would justify jurisdiction. The practical consequence is that the District Court’s partial final judgment dismissing the claims against the corporate defendants stands, leaving Gligorov without a forum in the United States to pursue these specific claims against those entities. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.