Lance v. Wilson, 811 F. Supp. 2d 106

Plaintiff Jimmy Lance filed a civil action against defendant Michael P. Wilson in the District of Columbia, alleging Title VII discrimination due to bad references.
Defendant moves to dismiss for lack of personal jurisdiction, improper venue, and failure to state a claim.
The complaint asserts employment termination and a resulting adverse impact on employment prospects between July 12 and December 17, 2009.
Plaintiff seeks $50,000 plus costs and interest, premised on Title VII (42 U.S.C. § 2000e et seq.).
The court grants the motion to dismiss for lack of personal jurisdiction, failure to state a claim, and improper venue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has personal jurisdiction over Wilson	Lance argues long-arm contacts via contracts with DoD and DC presence.	Wilson resides in Kentucky; no DC domicile or principal place of business.	No personal jurisdiction; insufficient minimum contacts.
Whether Lance states a Title VII claim against Wilson	Complaint references Title VII provisions.	Plaintiff fails to show Wilson as an employer or discriminatory motive based on protected status.	Failure to state a claim; plaintiff absent employer status and protected-class discrimination facts.
Whether venue is proper in the District of Columbia	Events occurred at Fort Belvoir; potential venue in VA or KY.	DC venue not established by plaintiff’s residence or defendant’s activities.	Venue improper; DC district not proper.

Int'l Shoe Co. v. Washington, 326 U.S. 310 (Supreme Court 1945) (established due process minimum contacts standard)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (Supreme Court 1985) (purposeful availment standard for personal jurisdiction)
GTE Nw. Med. Svs. v. BellSouth Corp., 199 F.3d 1343 (D.C. Cir. 2000) (long-arm jurisdiction analysis under due process)
Ferrara v. United States, 54 F.3d 825 (D.C. Cir. 1995) (DC long-arm statute governs personal jurisdiction)