Edward F. St. Onge v. USAA Federal Savings Bank, 219 A.3d 1278

Edward F. St. Onge (Rhode Island resident) alleges an oral agreement with Charles Baird (Florida resident) to assist in a Florida will dispute; St. Onge would be paid from proceeds if Baird prevailed.
St. Onge performed work in Florida and Rhode Island and advanced expenses; after prevailing, Baird moved estate funds into his USAA (Texas) account and directed payments to several of St. Onge’s national credit‑card accounts.
USAA rescinded the credit‑card payments and returned a $9,644.33 check marked “Not Authorized.” St. Onge sued Baird and USAA in Rhode Island Superior Court to recover the funds.
The Superior Court dismissed Baird for lack of personal jurisdiction (Jan. 28, 2017). A default against USAA was vacated and USAA’s motion to dismiss for lack of personal jurisdiction was granted (June 29, 2018).
St. Onge appealed pro se. The Rhode Island Supreme Court reviewed personal‑jurisdiction de novo and affirmed both Superior Court orders, remanding the papers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rhode Island has general jurisdiction over USAA	USAA’s online services, advertising, ATMs, and presence make it “at home” in RI	USAA is incorporated and headquartered in Texas; not essentially at home in RI	No general jurisdiction — USAA is not incorporated, headquartered, nor essentially at home in RI (Daimler governs)
Whether Rhode Island has specific jurisdiction over USAA	USAA looted funds from a RI resident and rescinded payments to accounts used from RI	USAA acted at Baird’s direction; rescinded payments were to out‑of‑state creditors and not targeted at RI	No specific jurisdiction — USAA’s actions were on behalf of Baird and not purposefully availed to RI; plaintiff’s unilateral contacts insufficient
Whether Rhode Island has specific jurisdiction over Baird	St. Onge contends sufficient contacts exist and jurisdiction would not offend fair play	Baird stresses burden of travel, most events occurred in Florida, and Florida has stronger interests	No specific jurisdiction — although minimum contacts were found, the Gestalt (fairness) factors (burden, convenience, state interests) weigh against litigating in RI

Daimler AG v. Bauman, 571 U.S. 117 (2014) (general‑jurisdiction standard: corporation is subject to general jurisdiction where incorporated, has principal place of business, or is "essentially at home")
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (general jurisdiction principles informing Daimler)
Bristol‑Myers Squibb Co. v. Superior Court of California, 137 S. Ct. 1773 (2017) (specific jurisdiction requires affiliation between forum and the underlying claim)
International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts and fair play inquiry foundation)
Rose v. Firstar Bank, 819 A.2d 1247 (R.I. 2003) (Rhode Island standard for specific jurisdiction and purposeful availment)
Cassidy v. Lonquist Mgmt. Co., LLC, 920 A.2d 228 (R.I. 2007) (plaintiff’s allegations accepted for prima facie jurisdictional showing)
Cerberus Partners, L.P. v. Gadsby & Hannah, LLP, 836 A.2d 1113 (R.I. 2003) (discussing Gestalt factors and reasonableness inquiry)
BNSF Ry. Co. v. Tyrrell, 137 S. Ct. 1549 (2017) (limits on general jurisdiction post‑Daimler)