Alabama Dynamics Inc v. McDaniel Machinery Inc, 2:12-cv-01929

Alabama Dynamics contracted to purchase a High Precision Moving Double Column Vertical Machining Center from Sharp; Sharp arranged with Port Alliance to ship the machine from Taiwan to Calera, Alabama.
Port Alliance hired National Drayage to transport the machinery from the Savannah port to Alabama Dynamics in Calera; the shipment is the focal point of the dispute.
During transit, the vehicle carrying the machine struck a bridge overpass, causing substantial damage to the machinery; Sharp claims the location of the accident (Georgia or Alabama) is not yet determined by discovery.
Port Alliance’s contacts with Alabama are limited to this shipment; it is a New Jersey corporation with no Alabama registration or physical presence, and it did not contract directly with Alabama entities for this shipment.
The case was removed from state court to federal court; Sharp’s Third-party Complaint was later amended to include Carmack Amendment and COGSA claims; the court severed underlying state-law claims and addressed preemption, jurisdiction, and failure to state a claim.
The court ultimately dismissed Sharp’s Counts I–III (state-law claims) as completely preempted, granted Port Alliance’s lack of personal jurisdiction and dismissed its claims, and denied National Drayage’s Rule 12(b)(6) challenge to Sharp’s Carmack Amendment and COGSA claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Complete preemption of state-law claims	Sharp contends preemption by Carmack/COGSA.	Port Alliance and National Drayage argue complete preemption applies; jurisdiction already exists.	Counts I–III dismissed as completely preempted.
Personal jurisdiction over Port Alliance	Sharp asserts Port Alliance had sufficient minimum contacts with Alabama.	Port Alliance has minimal, isolated contacts; not enough for jurisdiction.	Port Alliance dismissed for lack of personal jurisdiction.
Failure to state a claim under Carmack/COGSA	Sharp pled damages and delivery in good condition with later damage; Carmack/COGSA viable.	National Drayage argues insufficiency under Rule 12(b)(6).	Counts IV–V survive; Carmack and COGSA claims adequately pled.

Chung v. NANA Development Corp., 783 F.2d 1124 (4th Cir. 1986) (support for jurisdiction based on forum-related activity)
Shao v. Sea Horse Container Lines, 72 F.3d 128 (Table) (4th Cir. 1995) (insufficient minimum contacts where defendant did not engage Alabama activities)
Pepsi-Cola Bottling Co. of Ft. Lauderdale-Palm Beach, Inc. v. Buffalo Rock Co., 593 F. Supp. 1559 (N.D. Ala. 1984) (single shipment may establish jurisdiction; but facts distinguishing here)
Delong Equip. Co. v. Washington Mills Abrasive Co., 840 F.2d 843 (11th Cir. 1988) (tests for personal jurisdiction under long-arm statute and due process)
Polo Ralph Lauren, L.P. v. Tropical Shipping & Constr. Co., 215 F.3d 1217 (11th Cir. 2000) (COGSA considerations in carrier liability)
Watts v. Florida Int’l Univ., 495 F.3d 1289 (11th Cir. 2007) (pleading standards under Twombly/Iqbal)