151 So. 3d 1075
Ala.2014Background
- Plaintiffs Brantley filed suit in Hale County against Builders Transportation Company, LLC and Bassett for failing to pay $10,000 for information on a missing Builders trailer.
- Merches, an employee of Builders, was added as a defendant in July 2012 with the same claims.
- Merches moved to dismiss for lack of personal jurisdiction, attaching his Tennessee affidavit claiming minimal Alabama contacts.
- Plaintiffs countered with an Alabama incident report showing Merches’ role in locating the trailer and the ensuing arrest in Alabama.
- Trial court denied Merches’ Rule 12(b)(2) motion in April 2013 and denied a second motion in May 2013; Merches sought mandamus relief.
- Court grants mandamus, directing dismissal for lack of personal jurisdiction; discussion of other arguments pretermitted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Alabama has specific personal jurisdiction over Merches | Brantleys argue sufficient minimum contacts. | Merches asserts no purposeful availment and random contacts. | Yes, lacked minimum contacts; dismissal ordered. |
Key Cases Cited
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (minimum contacts and purposeful availment framework)
- Ex parte Alamo Title Co., 128 So.3d 700 (Ala.2013) (lack of minimum contacts with Alabama; ongoing relationship not shown)
- Ex parte Covington Pike Dodge, Inc., 904 So.2d 226 (Ala.2004) (contacts alone not enough; must show purposeful availment)
- Ex parte Bufkin, 936 So.2d 1042 (Ala.2006) (discusses principles of personal jurisdiction)
- Hiller Investments, Inc. v. Insultech Group, Inc., 957 So.2d 1111 (Ala.2006) (Rule 4.2(b) scope limited to constitutional due process)