H2O Environmental Inc. v. Proimtu MMI, LLC
162 Idaho 368
| Idaho | 2017Background
- H2O Environmental, an out-of-state company registered to do business and with an office in Boise, contracted with Nevada LLC Proimtu to manage employment (hiring, wage reporting, payroll) for a Nevada construction project.
- Before forming the oral contract, H2O provided Proimtu a W-9 showing a Boise address, directed payroll processing through a Boise bank, and requested reimbursement checks be sent to Boise.
- H2O performed all contract duties from its Boise office (pre-employment screening, Davis-Bacon reporting, payroll via Boise bank); Proimtu sent wage info by email to Boise and mailed reimbursement checks to Boise.
- A DOL investigation later reclassified some workers, requiring additional wages and employment taxes; H2O paid the employment taxes and sought reimbursement from Proimtu, which did not respond.
- H2O sued in Idaho; Proimtu moved to dismiss for lack of personal jurisdiction. The district court granted dismissal; H2O appealed. The Idaho Supreme Court vacated and remanded, holding Idaho courts may constitutionally exercise specific jurisdiction over Proimtu.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Idaho has personal jurisdiction over Proimtu | Proimtu purposefully availed itself of Idaho by contracting with H2O after being informed H2O would perform services from Boise, receiving Boise W-9, sending emails and checks to Boise, and relying on Boise payroll processing | Contacts were insufficient to give fair warning or satisfy Due Process for jurisdiction in Idaho | Court held contacts were sufficient for specific jurisdiction: Proimtu knew H2O would perform work from Boise and purposefully availed itself of Idaho benefits and protections |
| Whether Proimtu’s filing of a statement of costs was a general appearance (and thus waived challenge) | H2O argued filing the statement of costs was a general appearance invoking jurisdiction | Proimtu contended it was not a general appearance | Court did not decide this issue because dismissal for lack of jurisdiction was vacated; remanded for further proceedings |
| Attorney fees on appeal sought by Proimtu under Idaho Code §12-120 | N/A (Proimtu sought fees as prevailing party) | H2O opposed | Court denied fees because Proimtu was not the prevailing party after reversal |
Key Cases Cited
- St. Alphonsus Reg'l Med. Ctr. v. Washington, 123 Idaho 739 (1993) (two-step personal jurisdiction inquiry: long-arm statute and due process)
- Houghland Farms, Inc. v. Johnson, 119 Idaho 72 (1990) (standard for reviewing dismissal for lack of personal jurisdiction; view facts favoring nonmoving party)
- Southern Idaho Pipe & Steel Co. v. Cal-Cut Pipe & Supply, Inc., 98 Idaho 495 (1977) (Idaho long-arm statute construed broadly)
- Schneider v. Sverdsten Logging Co., Inc., 104 Idaho 210 (1984) (due process protections required for out-of-state defendants)
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts standard for due process)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (fair warning and reasonableness in asserting jurisdiction)
- Hanson v. Denckla, 357 U.S. 235 (1958) (defendant must purposefully avail itself of forum State)