102 F. Supp. 3d 375
D. Mass.2015Background
- Seton Hall University, a New Jersey educational corporation, is defendant; plaintiff Matos is a Massachusetts resident and former student.
- Seton Hall mailed admission and a four-year scholarship offer to Plaintiff in Shrewsbury, MA, which Plaintiff accepted for Fall 2012 enrollment.
- Plaintiff experienced a depressive episode in freshman year, withdrew, re-enrolled Fall 2013, and later was involved in a dorm incident leading to allegations of drug paraphernalia and related disciplinary action.
- Plaintiff alleges breach of contract (Counts I), breach of a duty to provide fairness (Count II), and disability discrimination under New Jersey and federal law (Counts III–IV).
- Seton Hall moved to dismiss for lack of personal jurisdiction or improper venue, or in the alternative, to transfer venue to the District of New Jersey; the court denied the motion to dismiss and declined to transfer.
- The court held there is specific jurisdiction over Seton Hall in Massachusetts based on its Massachusetts recruitment, admissions communications, and foreseeable injuries to Plaintiff.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Massachusetts has specific jurisdiction over Seton Hall for all claims. | MA activity (recruiting, admissions offer) relates to Plaintiff’s claims. | Contacts are insufficient to satisfy due process. | Yes; specific jurisdiction exists for all claims. |
| Whether Seton Hall’s Massachusetts activities satisfy purposeful availment and relatedness. | Recruitment and admission communications show purposeful availment and nexus to claims. | Contacts do not demonstrate purposeful availment related to all claims. | Yes; purposeful availment and relatedness satisfied. |
| Whether venue is proper in this district or transfer is warranted. | Venue proper due to personal jurisdiction. | Possible transfer to District of New Jersey warranted. | Venue proper; transfer denied. |
Key Cases Cited
- Negron-Torres v. Verizon Commc’ns, Inc., 478 F.3d 19 (1st Cir.2007) (three-part specific jurisdiction test)
- Phillips Exeter Acad. v. Howard Phillips Fund, Inc., 196 F.3d 284 (1st Cir.1999) (three-step relatedness, purposeful availment, fairness test)
- Nowak v. Tak How Inv. Ltd., 94 F.3d 708 (1st Cir.1996) (test between proximate and but-for causation; foreseeability)
- Hahn v. Vermont Law School, 698 F.2d 48 (1st Cir.1983) (out-of-state admissions communications support jurisdiction)
- Sigros v. Walt Disney World Co., 129 F.Supp.2d 56 (D.Mass.2001) (nexus where forum activity fosters contractual relationship)
- Ticketmaster-New York, Inc. v, Alioto, 26 F.3d 201 (1st Cir.1994) (gestalt factors for minimum-contacts analysis)
- Daynard v. Ness, Motley, Loadholt, Richardson & Poole, P.A., 290 F.3d 42 (1st Cir.2002) (Massachusetts long-arm statute permits reach consistent with due process)