Meyer v. Race City Classics, LLC
235 N.C. App. 111
| N.C. Ct. App. | 2014Background
- Meyer, Nebraska resident, purchased a car from Race City Classics, NC, for $21,000 after negotiations led by Alphin, an owner of the NC dealership.
- Meyer wired $21,000 to Defendant; negotiations occurred via telephone and email with shipping planned to Nebraska.
- Car delivered to Meyer in Nebraska; Meyer alleged the car was not as represented and sought a refund.
- Nebraska court entered a default judgment against Defendant for $8,942.30 for car-repair costs.
- Meyer docketed the Nebraska foreign judgment in Iredell County, NC, and Defendant moved for relief from the foreign judgment.
- NC trial court held Defendant lacked minimum contacts with Nebraska, granted relief from the Nebraska judgment, and Plaintiff appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Nebraska has specific personal jurisdiction over Defendant | Defendant engaged in negotiations, contracted with a Nebraska resident, and directed delivery to Nebraska. | Defendant argues no sufficient minimum contacts with Nebraska. | Yes; Nebraska had specific personal jurisdiction. |
| Whether the Nebraska foreign judgment is entitled to full faith and credit/Given due process | Foreign judgment should be enforced in NC as valid under full faith and credit. | Nebraska lacked personal jurisdiction, rendering the judgment void. | Foreign judgment valid and enforceable in NC. |
| Whether the contract alone can support personal jurisdiction despite lack of physical presence in Nebraska | Contract bearing substantial connection to Nebraska supports jurisdiction. | One-time sale without sustained Nebraska presence is insufficient. | Contract had substantial connection; due process satisfied. |
Key Cases Cited
- International Shoe Co. v. State of Washington, 326 U.S. 310 (U.S. Supreme Court 1945) (establishes minimum contacts and due process for jurisdiction)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. Supreme Court 1980) (foreign judgments require due process compliance for full faith and credit)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. Supreme Court 1985) (purposeful direction and relatedness for specific jurisdiction)
- McGee v. International Life Insurance Co., 355 U.S. 220 (U.S. Supreme Court 1957) (single contract can suffice for jurisdiction with substantial forum connection)
- Williamson Produce, Inc. v. J.H. Satcher, Jr., 122 N.C. App. 589 (N.C. App. 1996) (contract bears substantial connection to forum; foreseeability of suit)
- Quality Pork Intern. v. Rupari Food Services, Inc., 267 Neb. 474 (Nebraska Supreme Court 2004) (sufficient contacts with Nebraska can support specific jurisdiction)
- Automotive Restyling Concepts, Inc. v. Central Service Lincoln Mercury, Inc., 92 N.C. App. 372 (N.C. App. 1988) (foreign judgment enforcement requires constitutional due process and statutory jurisdiction)