76 F. Supp. 3d 154
D.D.C.2014Background
- Plaintiffs Associated Producers, Ltd. and Simcha Jacobovici sue Vanderbilt University and Jensen for intentional interference with prospective economic advantage and business relations related to a National Geographic documentary project.
- Jensen acted as a National Geographic consultant on the Jerusalem cave documentary; Vanderbilt allegedly approved and encouraged Jensen’s involvement as part of its employment duties.
- National Geographic, headquartered in DC, held a consultants panel in DC in May 2011 that Jensen attended.
- Plaintiffs allege Jensen used her Vanderbilt position to transmit rumors and defaming information to NatGeo officials and panel members, causing NatGeo to halt the project.
- Plaintiffs later sold documentary rights to Discovery Channel; they contend the delay caused significant economic harm and damaged NatGeo relationships; suit filed March 12, 2014 against Jensen and Vanderbilt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court has personal jurisdiction over Jensen and Vanderbilt | Jensen’s DC-based consulting relationship with NatGeo creates minimum contacts; Vanderbilt’s control over Jensen implies agency. | Jensen’s actions were not sufficiently connected to the forum; emails/calls alone do not establish transacting business; no agency established for Vanderbilt. | Court has specific jurisdiction over Jensen; Vanderbilt dismissed for lack of personal jurisdiction. |
| Whether venue is proper in DC or transfer to Tennessee is warranted | DC is proper; Jensen’s DC-centered conduct and NatGeo ties anchor events in DC. | Venue should be in Tennessee; transfer to MD Tennessee for convenience. | Venue proper in DC; transfer denied. |
| Whether the case should be transferred to the Middle District of Tennessee | DC forum is appropriate; substantial connection to DC; private/public factors favor DC. | Transfer to TN more convenient for Jensen; differing governing law could complicate case. | Transfer not warranted; keep case in DC. |
| Whether the statute of limitations bars the claims | DC discovery rule may apply given defamation-like intertwined conduct; discovery in July 2013. | DC discovery rule not clearly adopted; claims timeliness tied to 2011 publication. | Discovery rule likely applies; claims timely under DC defamation-like limitations. |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (Supreme Court 1945) (minimum contacts required for due process)
- World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (Supreme Court 1980) (foreseeability and purposeful availment)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (Supreme Court 1985) (purposeful availment and long‑arm jurisdiction standard)
- McGee v. International Life Ins. Co., 355 U.S. 220 (Supreme Court 1957) (state's interest in protecting its citizens; contracting with a resident of the forum)