The case of the day is Rana v. Islam (S.D.N.Y. 2015). Mashud Rana alleged that the defendant, Monirul Islam, Bangladesh’s former consul general in New York, and his wife, Fahima Tahsina Prova, had lured him to the United States to work as a domestic servant with false promises and then mistreated him. We’ve seen similar cases before, including my bête noire, Gurung v. Malhotra. Here, Islam moved to dismiss for want of subject matter jurisdiction and on grounds of insufficient service of process.