Brooks v. Harris, 808 F. Supp. 2d 206

Plaintiff Marcus Brooks filed suit in DC Superior Court alleging false arrest, malicious accusation, and malicious prosecution arising from his West Virginia cocaine arrest.
Case was removed to this Court; Dean, Lockhart, and Plumer were dismissed; remaining defendants were Charles Town Police Department (CTPD) and Harris.
CTPD and Harris moved to dismiss for insufficient service of process and lack of personal jurisdiction; Brooks opposed.
Court held it has no personal jurisdiction over Harris or CTPD, so it need not reach service arguments.
Legal standard applicable to Rule 12(b)(2) requires plaintiff to show factual basis for jurisdiction; court may consider outside pleadings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has general jurisdiction over the defendants	Brooks contends defendants have forum contacts.	Defendants lack continuous and systematic contacts with DC.	No general jurisdiction; contacts insufficient.
Whether the court has specific jurisdiction under the DC long-arm statute	Plaintiff argues DC connections via conduct or effects in DC.	Events occurred in WV; no DC-specific contact or directed activity toward DC residents.	No specific jurisdiction; DC long-arm statute not satisfied.

Int'l Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts required for due process)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful direction toward forum; relatedness to suit)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (specific vs general jurisdiction; 'arise out of' contact)
Gorman v. Ameritrade Holding Corp., 293 F.3d 506 (D.C. Cir. 2002) (stringent minimum contacts test for general jurisdiction)
FC Inv. Group LC v. IFX Markets, Ltd., 529 F.3d 1087 (D.C. Cir. 2008) (specific vs general jurisdiction; long-arm analysis)
United States v. Ferrara, 54 F.3d 825 (D.C. Cir. 1995) (specific jurisdiction framework within DC Circuit)