LAMBERT LAW FIRM PROF. CORP. v. HANSEL
1:24-cv-02396
| D.D.C. | Dec 5, 2024Background
- George Lambert, a Florida attorney, and his law firm represented Mykalai Kontilai in an SEC enforcement action in New York.
- Lambert's legal fees were to be paid from Kontilai's directors and officers (D&O) insurance policy.
- Cary Hansel, a Maryland attorney and his firm, were later retained by Kontilai as co-counsel in the same matter.
- Lambert alleges Hansel interfered with his business relationship with Kontilai and obtained a substantial insurance payout for his own fees, reducing amounts available to Lambert.
- Lambert sued Hansel and his firm in the District of Columbia, asserting claims of fraud and interference, and Hansel moved to dismiss for lack of personal jurisdiction among other grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal Jurisdiction under D.C. Law | Hansel has sufficient D.C. contacts | No relevant contacts with D.C.; all actions out | No personal jurisdiction; none of Hansel's acts or injuries occurred in D.C. |
| Due Process (General/Specific Jurisdiction) | Hansel licensed and active in D.C. courts | Residence/business in Maryland, not D.C. | Due Process not satisfied; Hansel not at home/targeting D.C. |
| Statutory Jurisdiction under D.C. Code | Jurisdiction under D.C. statutes which apply | Statutes require domicile or injury in D.C., not met | None of the D.C. statutes confer jurisdiction here |
| Motion to Strike Certain Pleadings | Material is relevant | Material is impertinent/scandalous | Reserved decision pending Rule 11 motion outcome |
Key Cases Cited
- Crane v. N.Y. Zoological Soc’y, 894 F.2d 454 (D.C. Cir. 1990) (discusses burden for establishing personal jurisdiction and injury in the forum)
- GTE New Media Servs. Inc. v. BellSouth Corp., 199 F.3d 1343 (D.C. Cir. 2000) (articulates requirements for personal jurisdiction under due process and local law)
- Daimler AG v. Bauman, 571 U.S. 117 (2014) (sets standard for general personal jurisdiction)
- Bristol-Myers Squibb Co. v. Superior Ct. of Cal., 582 U.S. 255 (2017) (explains specific personal jurisdiction requirements)
- Calder v. Jones, 465 U.S. 783 (1984) (sets out the express aiming test for specific jurisdiction)
- Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574 (1999) (court must dismiss when lacking personal jurisdiction)