Barth v. Walt Disney Parks & Resorts U.S., Inc.
697 F. App'x 119
| 3rd Cir. | 2017Background
- Michael Barth alleged he was bitten by a copperhead snake at Walt Disney World Resort in Florida; he and his wife sued Disney entities in Pennsylvania state court for negligence.
- Defendants (Walt Disney Parks and Resorts U.S., Inc. and The Walt Disney Company) removed the action to federal court in the Eastern District of Pennsylvania.
- Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(2) for lack of personal jurisdiction.
- The District Court granted the motion, finding no general jurisdiction over the Disney defendants in Pennsylvania.
- The Barths appealed, arguing Disney was amenable to general jurisdiction in Pennsylvania based on extensive contacts (including affiliated companies’ activities).
- The Third Circuit affirmed, concluding the defendants were not "at home" in Pennsylvania and that imputing affiliates’ contacts was unwarranted; jurisdictional discovery was unnecessary.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court has general jurisdiction over Disney entities in PA | Disney’s affiliated companies do substantial business in PA, so Disney is essentially at home there | Disney is incorporated/has principal place of business elsewhere (FL/CA/DE); not at home in PA | No general jurisdiction; defendants not at home in PA |
| Whether this is an "exceptional case" justifying departure from the at-home rule | The scale/nature of contacts (through affiliates) makes this exceptional | Contacts of affiliates cannot be imputed to these defendants absent evidence | Not an exceptional case; affiliates’ contacts not imputed |
| Whether contacts alleged suffice to require jurisdictional discovery | Plaintiffs need discovery to prove jurisdictional facts | Existing record shows lack of jurisdiction; discovery would be futile | Discovery would have been futile on this record |
| Standard of review / burden on plaintiff | Barths argue facts support jurisdiction | Defendants assert plaintiff bears burden to prove jurisdiction by competent evidence | Court reviews jurisdiction de novo; plaintiff failed to meet burden |
Key Cases Cited
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (holding general jurisdiction exists only where a corporation is essentially at home)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (establishing due-process framework for personal jurisdiction based on contacts)
- Daimler AG v. Bauman, 134 S. Ct. 746 (reinforcing that a corporation is at home in its state of incorporation or principal place of business; exceptional cases rare)
- Metcalfe v. Renaissance Marine, Inc., 566 F.3d 324 (plaintiff bears burden to prove jurisdiction by affidavits/competent evidence)
- Pennzoil Prods. Co. v. Colelli & Assocs., Inc., 149 F.3d 197 (standard of review for district court’s personal jurisdiction determination)