84 F. Supp. 3d 421
E.D. Pa.2015Background
- Plaintiffs sued Tennant Truck Lines, Inc. (an Illinois corporation) and its driver Scott McMeen (Illinois domiciliary) in the Eastern District of Pennsylvania for injuries from a June 10, 2013 truck accident that occurred in Illinois.
- Tennant moved to dismiss for lack of personal jurisdiction and improper venue (or transfer). McMeen later moved on the same grounds.
- Jurisdictional discovery produced Tennant-related facts: thousands of deliveries/pickups in Pennsylvania (2010–14), Pennsylvania revenue (~$0.88–1.6M annually), substantial vehicle miles and fuel purchases in PA, three Pennsylvania-based employees who garaged company vehicles, and modest PA tax filings/payments.
- Discovery as to McMeen showed limited contacts with Pennsylvania: one cargo pickup (Apr. 25, 2013) and approximately 14 trips passing through Pennsylvania during 2012–13; he is domiciled and served in Illinois.
- The core question: whether, under Goodyear and Daimler, Pennsylvania courts may exercise general (all-purpose) jurisdiction over Tennant or McMeen based on these contacts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pennsylvania has general jurisdiction over Tennant (corporation) | Tennant’s continuous, systematic business in PA (deliveries, revenue, employees, miles driven, taxes) suffices for general jurisdiction | Tennant is an Illinois corporation with principal place of business in Illinois; PA contacts are insufficient under Goodyear/Daimler to render it “essentially at home” in PA | Court: No general jurisdiction. Tennant’s PA contacts, though regular, do not make it “at home” in PA; dismissal for lack of personal jurisdiction granted |
| Whether Pennsylvania has general jurisdiction over McMeen (individual) | McMeen’s repeated travel through PA and a PA pickup are continuous and systematic contacts justifying general jurisdiction | McMeen is domiciled in Illinois, was served in Illinois, and has no domicile/presence/consent in PA; PA contacts are insufficient | Court: No general jurisdiction. Individual general jurisdiction requires domicile/presence/consent in PA; dismissal for lack of personal jurisdiction granted |
| Whether case should be transferred rather than dismissed | Plaintiffs sought to keep forum or have case transferred to an appropriate forum | Defendants argued dismissal for lack of jurisdiction; alternative transfer requests considered | Court: In interest of justice, transfers the action to the U.S. District Court for the Central District of Illinois rather than dismissing |
Key Cases Cited
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (2011) (general jurisdiction exists only where a corporation’s affiliations are so continuous and systematic as to render it “essentially at home”)
- Daimler AG v. Bauman, 134 S. Ct. 746 (2014) (reiterating the “at home” standard and limiting general jurisdiction to a corporation’s place of incorporation and principal place of business except in exceptional cases)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts and due process framework for personal jurisdiction)
- Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (1952) (textbook exception where a corporation’s temporary, principal place of business in the forum justified general jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (contacts consisting of purchases and occasional activities insufficient for general jurisdiction)