Arden v. East Coast Assemblers Incorporated, 2:14-cv-02290

Background

Plaintiffs sue East Coast Assemblers, Inc. and Individual Defendants for unpaid overtime under the FLSA.
East Coast Assemblers is a New Jersey corporation with Florida-based officers; principal place of business appears to be Florida.
Individual Defendants are Florida residents; Glenn Schneider is an officer/director; Jenny and Joseph Schneider are not listed as officers but are tied to East Coast Assemblers.
Plaintiffs allege Defendants failed to pay overtime premiums for hours over 40 for at least three years.
East Coast Assemblers counterclaims against Plaintiffs; Defendants move to dismiss for lack of personal jurisdiction; Counterdefendants move to dismiss counterclaims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has personal jurisdiction over the Individual Defendants	Plaintiffs contend substantial Arizona contacts exist via defendants' roles and visits.	Individual Defendants argue no substantial, continuous contacts; only minimal association with corporation and one Arizona visit.	Lacks general and specific jurisdiction over individuals.
Whether the counterclaims are properly maintainable in this FLSA action	East Coast Assemblers asserts permissive counterclaims with independent jurisdiction.	Counterdefendants argue counterclaims lack independent jurisdiction and are improper in FLSA cases.	Counterclaims dismissed without prejudice for lack of independent jurisdiction; leave to amend.

Key Cases Cited

Omeluk v. Langsten Slip & Batbyggeri A/S, 52 F.3d 267 (9th Cir. 1995) (basis for long-arm and due process analysis)
Int'l Shoe Co. v. Washington, 326 U.S. 310 (Supreme Court 1945) (minimum contacts required for jurisdiction)
Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (Supreme Court 1952) (general vs. specific jurisdiction framework)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (Supreme Court 1984) (corporate contacts and jurisdictional limits)
Calder v. Jones, 465 U.S. 783 (Supreme Court 1984) (effects test for purposeful availment)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (Supreme Court 1980) (random, foreseeable injury and jurisdictional due process)
Gates Learjet Corp. v. Jensen, 743 F.2d 1325 (9th Cir. 1984) (Arizona contacts must be more than incidental for general jurisdiction)
Am. Tel. & Tel. Co. v. Compagnie Bruxelles Lambert, 94 F.3d 586 (9th Cir. 1996) (parallel considerations in jurisdiction and pleading)
Data Disc, Inc. v. Systems Tech. Assoc., 557 F.2d 1280 (9th Cir. 1977) (conflicts between pleadings and affidavits in jurisdiction)
Valdez v. Allstate Ins. Co., 372 F.3d 1115 (9th Cir. 2004) (amount in controversy and jurisdictional pleading requirements)
Lowdermilk v. United States Bank Nat’l Assoc., 479 F.3d 994 (9th Cir. 2007) (jurisdictional amount in controversy requires factual support)
Davis v. Metro Productions, Inc., 885 F.2d 515 (9th Cir. 1989) (long-arm statute and corporate officer contact limitations)
Forsythe v. Overmyer, 576 F.2d 779 (9th Cir. 1978) (corporate officer contact with forum; not sufficient for jurisdiction)