Lion Fisheries LLC v. A1 Transmission & Marine Inc, 2:23-cv-00984

Plaintiff Lion Fisheries (Washington principal place of business) sued A1 Transmission & Marine, Inc. and J&H Marine, Inc. (both California corporations) for negligence and breach of contract related to repairs to the fishing vessel F/V ADVENTURE in 2022.
Defendants performed all repairs at their facilities in California; neither is incorporated or headquartered in Washington and have no ongoing Washington business contacts.
Plaintiff’s asserted basis for Washington jurisdiction: plaintiff’s principal place of business and ownership of the repaired property are in Washington.
Defendants moved to dismiss for lack of personal jurisdiction under Fed. R. Civ. P. 12(b)(2).
The court found that Washington’s maximum permissible jurisdictional reach still requires satisfaction of federal due-process limits and granted the motions to dismiss.

Issue	Plaintiff's Argument	Defendant's Argument	Held
General personal jurisdiction: whether defendants are "at home" in WA	Repairs to WA-owned property and plaintiff’s Washington residency make defendants subject to general jurisdiction	Defendants are California corporations, performed work in CA, no continuous/systematic contacts in WA	No general jurisdiction; contacts not "so continuous and systematic" to render defendants at home in WA
Specific personal jurisdiction: whether defendants purposefully directed activities at WA	Foreseeable effect on a Washington resident and ownership of the property in WA suffices	Work was performed in CA and was not expressly aimed at Washington; mere foreseeability is insufficient	No specific jurisdiction; plaintiff failed to allege purposeful direction or that the claims arise from forum-directed activities

International Shoe Co. v. Washington, 326 U.S. 310 (1945) (due-process minimum-contacts standard)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (limits on personal jurisdiction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (general jurisdiction requires contacts rendering a corporation "at home")
Daimler AG v. Bauman, 571 U.S. 117 (2014) (a corporation is at home in its place of incorporation and principal place of business)
Walden v. Fiore, 571 U.S. 277 (2014) (specific jurisdiction requires defendant’s purposeful direction at the forum)
Picot v. Weston, 780 F.3d 1206 (9th Cir. 2015) (plaintiff bears burden to establish jurisdiction)
Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797 (9th Cir. 2004) (tests for purposeful direction)
Pebble Beach Co. v. Caddy, 453 F.3d 1151 (9th Cir. 2006) (mere foreseeable effects in the forum are insufficient)
Shute v. Carnival Cruise Lines, 897 F.2d 377 (9th Cir. 1990) (high bar for general jurisdiction based on contacts)
Lake v. Lake, 817 F.2d 1416 (9th Cir. 1987) (cause of action must arise out of the defendant’s forum contact to support jurisdiction)