The case of the day is Barot v. Embassy of the Republic of Zambia (D.C. Cir. 2015). I first wrote about the case in April 2014. The question in the case was whether dismissal was proper for failure to comply with the service of process provisions of the FSIA. As I noted in my prior post, Barot failed to comply with the statute but part of the failure was the fault of the district court, not Barot herself. The district court had dismissed the case. I opined that the case was correctly decided in light of the requirement of strict compliance under the FSIA. Was the D.C. Circuit more forgiving?
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