Nasser Beydoun v. Wataniya Restaurants Holding
768 F.3d 499
6th Cir.2014Background
- Wataniya is a Qatari corporation with no U.S. or Michigan operations; Beydoun is a U.S. and Michigan citizen who moved to Qatar to be Wataniya’s CEO.
- Wataniya recruited Beydoun in Michigan (Starbucks meeting in Northville) and Beydoun later moved to Qatar to assume CEO duties.
- Beydoun made over ten business trips to Michigan and Wataniya purchased equipment from Michigan vendors.
- In Qatar, Beydoun faced accusations of mismanagement; Wataniya allegedly sought $13.7 million and detained Beydoun after revoking his exit visa.
- Beydoun sued Wataniya in Qatar; Wataniya sued Beydoun there; Beydoun could not return to Michigan until February 7, 2011; Plaintiffs filed this federal suit in 2012 alleging 13 counts including false imprisonment and abuse of process.
- District court dismissed for lack of personal jurisdiction; on appeal, court must analyze Michigan long-arm jurisdiction and due process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Michigan long-arm statute reaches Wataniya. | Wataniya’s Michigan contacts satisfy the statute. | Wataniya lacked Michigan contact beyond the recruitment and no specific acts. | Yes as to Wataniya under long-arm statute. |
| Whether plaintiffs prove the action arises from Wataniya’s Michigan contacts. | But-for Michigan contact caused Beydoun’s injuries. | Causes arose in Qatar, not from Michigan activities. | No proximal causation; not arising from Michigan contacts. |
| Whether exercise of jurisdiction would be reasonable under due process. | Wataniya should be subject to Michigan because of its contacts. | Most events occurred in Qatar; significant international interest and burden on Wataniya. | Unreasonable; due process not satisfied; no jurisdiction. |
Key Cases Cited
- Neogen Corp. v. Neo Gen Screening, Inc., 282 F.3d 883 (6th Cir. 2002) (requires prima facie jurisdiction showing and favors non-movant in dismissal context)
- CompuServe, Inc. v. Patterson, 89 F.3d 1257 (6th Cir. 1996) (burden on plaintiff to prove jurisdiction over each defendant)
- Days Inns Worldwide, Inc. v. Patel, 445 F.3d 899 (6th Cir. 2006) (jurisdictional analysis for each defendant; ‘slightest transaction’ suffices under Michigan long-arm)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (proximity/relatedness and purpose for due process in jurisdiction)
- Calphalon Corp. v. Rowlette, 228 F.3d 718 (6th Cir. 2000) (arising-from prong requires operative facts relate to forum contacts)
- Dean v. Motel 6 Operating L.P., 134 F.3d 1269 (6th Cir. 1998) (substantial connection requirement for in-forum activities)
- Southern Machine Co. v. Mohasco Indus., Inc., 401 F.2d 374 (6th Cir. 1968) (three-prong test for jurisdiction: purposeful availment, arising-from, and reasonable)
- Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102 (1987) (reasonableness factor in international jurisdiction analysis)
- International Shoe Co. v. Washington, 326 U.S. 310 (1937) (foundation of minimum contacts, due process)