SEARCH

Global NAPs, Inc. v. Verizon New England Inc.

Thank you for sharing!

Your article was successfully shared with the contacts you provided.

Before Lynch, Chief Judge, Boudin and Howard, Circuit Judges.

Global NAPs, Inc. (GNAPs) appeals from entry against it of a judgment for $57,716,714 for access charges that GNAPs owed but failed to pay Verizon New England Inc. (Verizon) for services Verizon provided between 2003 and 2006. Concerned that GNAPs could not pay a judgment, Verizon also successfully brought counterclaims alleging alter ego liability and disregard of the corporate form against GNAPs; its owner, Frank Gangi; and several GNAPs affiliates. These defendants appeal from the district court’s assertion of federal jurisdiction and grant of default judgment, which holds Gangi and the affiliates jointly liable for the sum GNAPs owes. We affirm.

In an issue of first impression for this court, we hold that 28 U.S.C. * 1367, enacted in 1990, gives federal courts supplemental jurisdiction over both compulsory and at least some permissive counterclaims. This alters this circuit’s former rule, adopted before the enactment of * 1367, that required permissive counterclaims to have an independent basis for jurisdiction. See McCaffrey v. Rex Motor Transp., Inc., 672 F.2d 246, 248 (1st Cir. 1982). Our ruling brings us into line with the Second and Seventh Circuits, as we describe below. Jones v. Ford Motor Credit Co., 358 F.3d 205, 210-14 (2d Cir. 2004); Channell v. Citicorp Nat’l Servs., Inc., 89 F.3d 379, 384-87 (7th Cir. 1996).

More From ALM

Premium Subscription

With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now

Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now

Bundle Subscriptions

Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now

From Data to Decisions

Dynamically explore and compare data on law firms, companies, individual lawyers, and industry trends.

Exclusive Depth and Reach.

Law.com Compass includes access to our exclusive industry reports, combining the unmatched expertise of our analyst team with ALM’s deep bench of proprietary information to provide insights that can’t be found anywhere else.

Big Pictures and Fine Details

Law.com Compass delivers you the full scope of information, from the rankings of the Am Law 200 and NLJ 500 to intricate details and comparisons of firms’ financials, staffing, clients, news and events.

British Legal Awards 2024

November 27, 2024
London

Celebrating achievement, excellence, and innovation in the legal profession in the UK.

Learn More

GlobeSt. Healthcare Real Estate 2024

December 02, 2024 - December 03, 2024
Scottsdale, AZ

Join the industry's top owners, investors, developers, brokers and financiers for the real estate healthcare event of the year!

Learn More

ThinkAdvisor LUMINARIES Awards 2024

December 11, 2024
Las Vegas, NV

This event shines a spotlight on how individuals and firms are changing the investment advisory industry where it matters most.

Learn More

Associate General Counsel, Global Employment

Role TitleAssociate General Counsel, Global EmploymentGrade F13Reporting ToSenior Legal Counsel, Global EmploymentProgram/Tool/ Department/U...

Apply Now ›

Associate Attorney

Ryan & Conlon, LLP, is a boutique firm specializing in insurance defense. We are a small eclectic practice with a busy and fast paced en...

Apply Now ›

INTELLECTUAL PROPERTY PROSECUTION PARALEGAL

INTELLECTUAL PROPERTY PROSECUTION PARALEGAL - NEW JERSEY OR NEW YORK OFFICESProminent mid-Atlantic law firm with multiple regional office lo...

Apply Now ›