Opelousas Hotel Group L L C v. D D G Construction Inc, 6:18-cv-01311

Plaintiff OHG contracted DDG for construction and AP Architecture for design of a Hampton Inn in Opelousas, Louisiana; OHG sued DDG and later added AP alleging construction defects.
AP maintained a North Carolina professional liability "claims-made, claims-reported" policy through broker RiskPro (a Texas company); AP alleges it first learned of OHG’s claim on March 24, 2020 and notified RiskPro on March 26, 2020.
Admiral (the insurer) contends it first received notice April 9, 2020 and that the 2019 policy had expired/renewed on April 7, 2020, so it denied coverage for late notice.
AP sued Admiral (and RiskPro) in North Carolina seeking coverage and damages for RiskPro’s alleged failure to timely notify Admiral; Admiral removed the NC suit to federal court; transfer issues to Louisiana were pending.
Admiral was later added to the Louisiana litigation; RiskPro moved to dismiss in the Western District of Louisiana for lack of personal jurisdiction.
The magistrate judge recommends granting RiskPro’s motion: RiskPro is Texas-incorporated, has its principal place of business in Texas, no Louisiana offices, a small percentage of Louisiana policies, and the challenged conduct occurred outside Louisiana — therefore no specific or general jurisdiction; dismissal without prejudice recommended.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Specific personal jurisdiction: can LA assert jurisdiction over RiskPro for AP’s failure-to-notify claims?	RiskPro brokered AP’s policy and failed to notify the insurer of claims arising from a Louisiana project, so jurisdiction is proper.	RiskPro’s alleged wrongful acts (brokerage/notice) occurred outside Louisiana for its North Carolina client and did not purposefully avail RiskPro to Louisiana.	No specific jurisdiction; AP failed to make a prima facie showing of purposeful availment or contacts related to the claim.
General personal jurisdiction: is RiskPro "at home" in Louisiana?	RiskPro has some Louisiana business and is registered with LA Department of Insurance, supporting general jurisdiction.	RiskPro is incorporated and headquartered in Texas, has no LA offices, and only a small fraction of policies in LA — not continuous/systematic contacts.	No general jurisdiction; RiskPro is not "at home" in Louisiana.
Fairness (reasonableness) of exercising jurisdiction	AP’s interest in relief and forum’s interests support jurisdiction.	Litigating in Louisiana would be burdensome; RiskPro lacks physical presence in LA.	Court found exercising jurisdiction would not be fair but did not reach this prong as contacts were insufficient.

Burger King Corp. v. Rudzewicz, 471 U.S. 462 (specific jurisdiction requires purposeful availment and relatedness between forum contacts and the claim)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (distinguishes specific from general jurisdiction; general jurisdiction is claim‑specific and limited)
Daimler AG v. Bauman, 571 U.S. 117 (general jurisdiction exists only where a corporation is "at home")
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (general jurisdiction requires continuous and systematic contacts)
Nuovo Pignone, SpA v. STORMAN ASIA M/V, 310 F.3d 374 (forum long-arm inquiry merges with due process analysis in Fifth Circuit)
Panda Brandywine Corp. v. Potomac Elec. Power Co., 253 F.3d 865 (plaintiff must show purposeful availment for prima facie specific jurisdiction)
Luv N'care, Ltd. v. Insta–Mix, Inc., 438 F.3d 465 (party invoking jurisdiction bears the burden to prove it exists)