Carteret Savings & Loan Assn. v. Jackson
United States Court of Appeals for the First Circuit
812 F.2d 36 (1st Cir. 1987)
The Jacksons (defendants) defaulted on a yacht loan from Carteret (plaintiff), which sued and obtained a default judgment in Florida federal court after the Jacksons filed no pleadings at all; after the yacht sale only partially satisfied the judgment, Carteret sued again in Massachusetts federal court to recover the balance, and the Jacksons tried to raise counterclaims for negligence, fraud, abuse of process, and unfair business practices, which the Massachusetts court barred as claims that should have been raised as compulsory counterclaims in the original Florida action.
Whether a party is barred from later asserting claims that could have been raised as compulsory counterclaims in a prior action, when that party filed no pleadings and had a default judgment entered against it in that prior action.