Bluetarp Financial, Inc. v. Matrix Construction Co., Inc.
709 F.3d 72
1st Cir.2013Background
- Matrix Construction Co., Inc. is a South Carolina corporation with its principal place of business in Anderson, SC.
- BlueTarp Financial, Inc. is a Delaware corporation with Maine operations; it supplied credit to Matrix via Contract Supply in SC.
- Matrix submitted a credit application through Contract Supply to BlueTarp, which included a Maine governing law and forum clause.
- BlueTarp approved the account; Matrix began receiving Maine-based billing and engaged in ongoing Maine-related credit activity.
- Matrix paid Contract Supply (not BlueTarp) through a Georgia lockbox; BlueTarp funded Matrix purchases and maintained billing from Maine.
- Maine federal court dismissed for lack of personal jurisdiction; First Circuit reversed, finding specific jurisdiction and relatedness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court had personal jurisdiction over Matrix. | BlueTarp argues Maine contacts and the forum clause establish jurisdiction. | Matrix contends contacts are insufficient for due process. | Yes; Maine court has specific jurisdiction over Matrix. |
Key Cases Cited
- Int'l Shoe Co. v. Washington, 326 U.S. 310 (Supreme Ct. 1945) (established minimum contacts for jurisdiction)
- Goodyear Dunlop Tire Operations, S.A. v. Brown, 131 S. Ct. 2846 (U.S. 2011) (requires general or specific jurisdiction based on contacts)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (choice-of-forum and relationship factors support jurisdiction)
- Phillips v. Prairie Eye Ctr., 530 F.3d 22 (1st Cir. 2008) (framework for specific jurisdiction: relatedness, purposefully availed, reasonableness)
- Adelson v. Hananel, 510 F.3d 43 (1st Cir. 2007) (gestalt factors and purposeful availment considerations)
- Carreras v. PMG Collins, LLC, 660 F.3d 549 (1st Cir. 2011) (relatedness, purposeful availment, reasonableness in context of forum state)