⚖ Oral Arguments, with Context

The Eleventh Circuit hears Solomon versus Isaac Btesh. The brothers are disputing their interests in a family bank in Panama and the proceeds of its sale. A family agreement referred disputes to procedures used by a Jewish congregation there. Solomon began arbitration in Panama, then pursued proceedings in Miami. A Miami rabbinical panel issued an award against Isaac, who did not participate in that arbitration. Solomon asked a Florida federal court to confirm the award, meaning turn it into an enforceable court judgment. The judge dismissed the petition for lack of personal jurisdiction: the court's power over Isaac. That differs from the arbitrators' authority under the family agreement. One route discussed here is Rule 4(k)(2), a federal rule for federal claims when no state's courts can exercise jurisdiction over the defendant. It looks beyond a single state, but exercising jurisdiction must still be constitutional. Another route, quasi in rem jurisdiction, concerns specified property, with recovery limited to that property rather than a general personal judgment. The judges also discuss dicta: observations in an earlier opinion that were not necessary to decide that case. Listen for the distinction between agreeing to arbitrate, choosing a particular tribunal, and giving an American court authority to enforce an award.

Solomon Btesh v. Isaac Btesh (No. 25-11265) — U.S. Court of Appeals for the Eleventh Circuit, argued November 3, 2026.