Dumitrascu v. Dumitrascu

Summary

The court affirmed dismissal without prejudice of Alin Dumitrascu’s federal action for lack of jurisdiction. Although the complaint invoked federal law and alleged fraud in prior Hague Convention proceedings, the action was an improper collateral attack on the earlier judgment that should have been presented to the court that entered it, including through a postjudgment motion. The court also held that an argument raised for the first time in a reply brief was waived.