DOERR v. UNIVERSITY OF DELAWARE
2:16-cv-02738
D.N.J.Jun 9, 2017Background
- Plaintiff Ayrton J. Doerr was a University of Delaware student from Sept. 2011 to May 2014 and was involved in an off-campus April 19, 2014 incident in Newark, Delaware that led to his arrest on assault/home-invasion allegations.
- UDel suspended Doerr five days after the incident, held a disciplinary hearing within ten days, and expelled him; criminal charges were never presented to a grand jury and the Delaware Attorney General later filed a notice of nolle prosequi ending the criminal investigation.
- Doerr sued UDel and several university officials (Individual Defendants) in the District of New Jersey asserting federal constitutional claims (including § 1983 procedural and substantive due process and privacy), breach of implied covenant of good faith and fair dealing, and negligent infliction of emotional distress.
- Defendants moved to dismiss for lack of personal jurisdiction, improper venue, and failure to state a claim; the Court considered briefs and decided without oral argument.
- The Court found that Doerr failed to plead facts establishing either general or specific personal jurisdiction in New Jersey because all relevant events and university actions occurred in Delaware and none of the individual defendants were alleged to be domiciled in New Jersey.
- The Court dismissed the Complaint without prejudice for lack of personal jurisdiction and granted Doerr 30 days to file an amended complaint addressing the deficiencies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction — general | UDel recruits NJ students and should anticipate being sued in their home state | Recruitment and student attendance do not render a university "at home" in NJ; individual defendants are not domiciled in NJ | Dismissed for lack of general jurisdiction; allegations insufficient to show defendants "at home" in NJ |
| Personal jurisdiction — specific | Forum choice entitled to weight; Plaintiffs' claims should proceed in NJ | No conduct linking defendants to NJ; alleged wrongdoing occurred in Delaware | Dismissed for lack of specific jurisdiction; claims do not arise from contacts with NJ |
| Venue | (Plaintiff argued forum choice appropriate) | Defendants moved that venue is improper in NJ | Court found venue argument unpersuasive but did not reach merits due to lack of jurisdiction |
| Failure to state a claim | Plaintiff asserted multiple federal and state claims | Defendants argued complaint fails plausibly to plead claims and lacks facts about most individual defendants | Court noted pleading defects (e.g., lack of specific facts re individual defendants) but did not decide merits because case dismissed for lack of jurisdiction |
Key Cases Cited
- Marten v. Godwin, 499 F.3d 290 (3d Cir. 2007) (federal courts may exercise personal jurisdiction to the extent authorized by state law)
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts standard for personal jurisdiction)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (defendant must reasonably anticipate being haled into forum)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (specific jurisdiction requires purposeful availment and suit arising out of contacts)
- Daimler AG v. Bauman, 134 S. Ct. 746 (2014) (general jurisdiction exists where entity is "at home")
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (2011) (distinguishes general and specific jurisdiction)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility pleading standard)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (due process limits on jurisdiction)