Knight v. Standard Chartered Bank, 531 F.Supp.3d 755

Plaintiffs Julian Knight (U.K. citizen) and Anshuman Chandra (Indian citizen) are former employees of Standard Chartered Bank (SCB) who allege they reported SCB’s evasion of U.S. sanctions and were thereafter retaliated against.
SCB is incorporated and headquartered in the U.K.; it operates branches including in Dubai and New York (the branches are not separate legal entities).
Plaintiffs brought federal FCA (31 U.S.C. § 3730(h)) and New York FCA (N.Y. Fin. Law § 191) retaliation claims; defendants moved to dismiss for lack of personal jurisdiction, failure to state a claim, and forum non conveniens.
Most alleged retaliatory acts occurred outside the U.S.; the FAC alleges limited New York-related conduct: (a) a 2014 call from SCB NY’s CEO to Knight’s New York employer leading to his departure, and (b) in 2017 an SCB NY employee (Steven Tong) prematurely removed Chandra’s name from records, harming his job prospects.
The Court dismissed the FCA claims for lack of personal jurisdiction as to SCB, declined supplemental jurisdiction over the NYFCA claims (no diversity), and dismissed the complaint in its entirety without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
General personal jurisdiction over SCB	SCB’s continuous business in New York (branches, licensing) makes it "at home" here	SCB is U.K.-incorporated/headquartered; having branches in U.S. does not make it "at home"	No general jurisdiction — foreign bank not "at home" in NY absent exceptional contacts
Specific personal jurisdiction (FCA retaliation)	Limited New York acts (calls/record changes) connect SCB to plaintiffs’ claims	New York contacts are isolated, post-dates employment, or conclusory; suit-related conduct occurred abroad	No specific jurisdiction — alleged New York acts too attenuated or post-employment to create substantial forum connection
Scope of FCA retaliation (timing of actionable conduct)	Plaintiffs rely on post-termination acts as retaliatory harm	Defendants argue § 3730(h) protects employees during employment, not post-employment acts	Court treats post-termination acts as generally not actionable under FCA; Knight’s NY incident postdated employment and could not support FCA jurisdiction
Jurisdiction over NYFCA claims (subject-matter: diversity/supplemental)	Plaintiffs pleaded diversity and sought to keep state claims in federal court	Defendants note all parties are foreign so § 1332(a)(2) diversity is lacking	No diversity; court declines to exercise supplemental jurisdiction and dismisses NYFCA claims without prejudice

Licci ex rel. Licci v. Lebanese Canadian Bank, SAL, 673 F.3d 50 (2d Cir. 2012) (personal-jurisdiction framework including service and long-arm analysis)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment and minimum-contacts analysis)
International Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (minimum contacts and due process foundation for jurisdiction)
Walden v. Fiore, 571 U.S. 277 (U.S. 2014) (requires suit‑related conduct that creates a substantial connection with the forum)
Daimler AG v. Bauman, 571 U.S. 117 (U.S. 2014) (general jurisdiction only where corporation is "at home")
Goodyear Dunlop Tires Ops., S.A. v. Brown, 564 U.S. 915 (U.S. 2011) (limits on general jurisdiction)
Ford Motor Co. v. Montana Eighth Judicial District Court, 141 S. Ct. 1017 (U.S. 2021) (distinguishing general and specific jurisdiction; forum-claim affiliation requirement)
In re Terrorist Attacks on Sept. 11, 2001, 714 F.3d 659 (2d Cir. 2013) (Second Circuit discussion of general jurisdiction standards)
United States ex rel. Chorches v. Am. Med. Response, Inc., 865 F.3d 71 (2d Cir. 2017) (elements required to plead an FCA retaliation claim)