Locke v. Fedex Freight, Inc., 1:12-cv-00708

Locke sues FedEx Freight and employees under Title VII, CADA, and §1981, later narrowing to §1981 claim only.
Jones moves to dismiss for insufficient service of process and lack of personal jurisdiction.
Court treats §1981 as governing, with personal involvement of the individual defendant required.
Jones lives in Arkansas and had minimal Colorado contacts; most relevant ties are 2–3 2008 visits linked to FedEx employment.
Colorado long-arm analysis proceeds under Rule 4(k)(1)(A) and §13-1-124(1) focusing on general vs. specific jurisdiction.
Court acknowledges Plaintiff’s pro se status and the standard for reviewing a Rule 12(b)(1)/(2) motion; Plaintiff bears burden to show prima facie jurisdiction and proper service.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Colorado has specific personal jurisdiction over Jones.	Locke contends Jones purposefully directed activities at Colorado and caused injuries here.	Jones asserts no Colorado contacts or injurious acts linked to him personally; no purposefully directed conduct.	Yes, specific jurisdiction is established under Colorado law.
Whether service of process was proper on Jones.	Service was effected via Jones’s attorney and facility contact; this suffices under Rule 4(e).	Plaintiff failed to personally serve Jones; counsel’s receipt does not count as proper service.	Not proper service initially, but extension to re-serve at correct address warranted.

International Shoe Co. v. Washington, 326 U.S. 310 (Supreme Court (1945)) (minimum contacts required for jurisdiction)
Hanson v. Denckla, 357 U.S. 235 (Supreme Court (1958)) (purposeful availment essential to jurisdiction)
Calder v. Jones, 465 U.S. 783 (Supreme Court (1984)) (journalist acts directed at forum support jurisdictional analysis)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (Supreme Court (1985)) (purposeful availment; contract-related jurisdictional ties)
Archangel Diamond Corp. v. Lukoil, 123 P.3d 1187 (Colo. 2005) (Colorado long-arm reaches due process; injury must be focus of tort and forum)