505 F.Supp.3d 16
D. Mass.2020Background
- Plaintiff injured at a Sky Zone trampoline park in Westborough, Massachusetts; Fun Spot Manufacturing built the park.
- CircusTrix Holdings, LLC is a Utah company that purchased the Westborough Sky Zone 14 months after the accident.
- Plaintiff sued Fun Spot and CircusTrix; CircusTrix moved to dismiss for lack of personal jurisdiction.
- Court reviewed personal jurisdiction under the Boit prima facie standard and Massachusetts long‑arm/constitutional limits.
- Plaintiff argued successor liability could permit jurisdiction over CircusTrix; no evidence supported successor‑liability factors.
- Court dismissed all counts against CircusTrix and remanded the remaining (unopposed) claims against Fun Spot to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Massachusetts has specific personal jurisdiction over CircusTrix for an injury that occurred before CircusTrix acquired the park | CircusTrix can be held to answer because successor liability makes the claim arise from its ownership of the Sky Zone | CircusTrix had no relevant contacts with Massachusetts at time of accident and did not own the park until 14 months later | No specific jurisdiction: plaintiff failed the relatedness proximate‑cause requirement because injury did not arise from CircusTrix's forum contacts |
| Whether successor liability binds CircusTrix to predecessor's liabilities (to create jurisdictional nexus) | Successor liability doctrines apply under Massachusetts law to hold purchaser liable | No evidence of assumption, de facto merger, continuation, or fraud—so successor liability does not apply | Plaintiff produced no evidence of the four successor‑liability factors; successor liability not established |
| Whether remaining claims should be remanded to state court after dismissal of CircusTrix | Remand requested for remaining claims against Fun Spot | CircusTrix opposed remand but its dismissal made opposition moot; Fun Spot did not oppose | Motion to remand allowed; remaining counts remanded to state court |
Key Cases Cited
- Boit v. Gar‑Tec Products, Inc., 967 F.2d 671 (1st Cir. 1992) (framework for assessing personal jurisdiction; prima facie standard)
- Platten v. HG Bermuda Exempted Ltd., 437 F.3d 118 (1st Cir. 2006) (courts construe plaintiff's jurisdictional allegations favorably and consider uncontested defendant facts)
- Int'l Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (minimum contacts and due process standard for personal jurisdiction)
- Baskin‑Robbins Franchising LLC v. Alpenrose Dairy, Inc., 825 F.3d 28 (1st Cir. 2016) (three‑part test for specific jurisdiction)
- Harlow v. Children's Hosp., 432 F.3d 50 (1st Cir. 2005) (rejects jurisdiction when nexus between claim and forum contacts is attenuated)
- Cambridge Literary Props., Ltd. v. W. Goebel Porzellanfabrik G.m.b.H. & Co., 295 F.3d 59 (1st Cir. 2002) (requires a proximate‑cause nexus between contacts and claim)
- Guzman v. MRM/Elgin, 567 N.E.2d 929 (Mass. 1991) (Massachusetts rules for successor liability)
- Automatic Sprinkler Corp. of Am. v. Seneca Foods Corp., 280 N.E.2d 423 (Mass. 1972) (Massachusetts long‑arm statute interpreted as coextensive with constitutional limits)