Goldman v. Trinity Sch. Med.
24-1827
2d Cir.Apr 14, 2025Background
- Jack Goldman, a New York resident, attended Trinity School of Medicine, a Caribbean institution in St. Vincent and the Grenadines, starting in 2016.
- Goldman alleged Trinity made false statements during his recruitment and improperly charged tuition; he sued for violations of New York General Business Law, breach of contract, and breach of warranty.
- The U.S. District Court for the Eastern District of New York dismissed the case for lack of personal jurisdiction over Trinity and its unnamed employees.
- Goldman appealed, arguing that Trinity’s contacts with New York were sufficient for jurisdiction and that he should have been allowed to amend his complaint.
- The Second Circuit reviewed the case de novo on jurisdiction and for abuse of discretion regarding leave to amend, ultimately affirming the district court’s dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal Jurisdiction | Trinity’s recruitment, marketing, and NY student body establish sufficient contacts. | Contacts were limited, non-targeted, and not purposefully directed to NY. | Trinity’s NY contacts insufficient for specific jurisdiction. |
| Nexus of Claims to NY | Prior NY clinical placement contracts and recruitment interviews link claims to NY. | Contracts ended before plaintiff’s involvement; no direct nexus to claims. | No articulable nexus; contacts not related to Goldman's claims. |
| Purposeful Availment | Trinity’s general marketing and NY student enrollment show purposeful availment. | Recruitment and marketing were nationwide, not NY-specific. | No purposeful availment shown through school’s activities. |
| Leave to Amend Complaint | Should be allowed to amend to cure defects. | Amendment would be futile; plaintiff failed to produce new facts supporting jurisdiction. | Denial of leave to amend was appropriate; amendment futile. |
Key Cases Cited
- Porina v. Marward Shipping Co., Ltd., 521 F.3d 122 (2d Cir. 2008) (de novo review of dismissal for lack of personal jurisdiction)
- D.H. Blair & Co., Inc. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (personal jurisdiction in diversity cases governed by forum state law and due process)
- Al Rushaid v. Pictet & Cie, 28 N.Y.3d 316 (N.Y. 2016) (requirements for personal jurisdiction under NY long-arm statute)
- Licci ex rel. Licci v. Lebanese Can. Bank, SAL, 673 F.3d 50 (2d Cir. 2012) (purposeful availment as criterion for transaction of business in NY)
- McGowan v. Smith, 52 N.Y.2d 268 (N.Y. 1981) (requirement of an articulable nexus for jurisdiction under NY long-arm statute)
- Best Van Lines, Inc. v. Walker, 490 F.3d 239 (2d Cir. 2007) (general marketing not sufficient for personal jurisdiction)
- Panther Partners Inc. v. Ikanos Commc’ns, Inc., 681 F.3d 114 (2d Cir. 2012) (review of denial of leave to amend based on futility)