McQueen v. Huddleston, 17 F. Supp. 3d 248

Plaintiff Donald McQueen filed suit in March 2018 under the Fair Debt Collection Practices Act against attorney Lee Huddleston, d/b/a Huddleston and Huddleston, Attorneys at Law, over attempts to collect a debt McQueen asserts was satisfied in 2006.
Defendant, appearing pro se, moved to dismiss on grounds including improper venue, lack of personal jurisdiction, insufficient process, service, and failure to join a necessary party.
The court previously denied a motion to dismiss and granted leave to amend to name the proper defendant in an October 10, 2013 order (2013 WL 5592804).
McQueen filed an amended complaint on November 11, 2013; defendant filed an untimely, procedurally hybrid submission on December 5, 2013, which included a motion to dismiss for lack of personal jurisdiction, an unsworn factual statement, and an answer.
The court considered the untimely submission and treated the December 5, 2013 filing as a motion to dismiss for lack of personal jurisdiction and an Answer; the court denied the jurisdictional portion and deemed the Answer the operative pleading.
The court held that, under CPLR 302(a)(1), it has personal jurisdiction over Huddleston based on defendant’s in-forum contacts arising from debt collection activities including a 2009 collection letter mailed into New York and telephone calls to the plaintiff, establishing a prima facie case and satisfying due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether New York CPLR § 302(a)(1) authorizes personal jurisdiction	McQueen asserts defendant purposefully directed activities at New York and transacted business through debt collection efforts in the state.	Huddleston contends there is no sufficient connection to New York to support jurisdiction.	Yes; CPLR § 302(a)(1) jurisdiction is established.
Whether the exercise of jurisdiction complies with due process	Plaintiff argues minimum contacts and reasonableness are satisfied by in-state communications and collection efforts.	Huddleston argues the in-state contacts are insufficient or unfair under due process.	Yes; exercise of jurisdiction is constitutional.

Robinson v. Overseas Military Sales Corp., 21 F.3d 502 (2d Cir. 1994) (establishes personal jurisdiction standards for nonresidents)
Kreutter v. McFadden, 71 N.Y.2d 460 (N.Y. 1988) (single act statute: one New York transaction suffices if purposeful)
Ball v. Metallurgie Hoboken-Overpelt, S.A., 902 F.2d 194 (2d Cir. 1990) (prima facie showing of jurisdiction may be made by affidavits and facts)
McGee v. International Life Ins. Co., 355 U.S. 220 (U.S. 1957) (minimum contacts can be established by in-state actions related to the dispute)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (foreseeability and purposeful availment considerations in due process)
Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102 (U.S. 1987) (two-component due process analysis for state jurisdiction)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (reasonableness and fair play considerations in jurisdiction)
Metropolitan Life Ins. Co. v. Robertson-Ceco Corp., 84 F.3d 560 (2d Cir. 1996) (outlines minimum contacts and reasonableness framework)
Sluys v. Hand, 831 F.Supp. 321 (S.D.N.Y. 1993) (debt collection letters into forum support jurisdiction)